Title
Homeowner's Association of the Philippines, Inc. vs. Municipal Board of the City of Manila
Case
G.R. No. L-23979
Decision Date
Aug 30, 1968
Homeowners challenged Manila's rental control ordinance as unconstitutional; Supreme Court ruled it void, citing indefinite duration and unreasonable property rights restrictions.

Case Digest (G.R. No. L-23979)

Facts:

  • Parties and Nature of the Case
    • Petitioners-Appellees: Homeowners' Association of the Philippines, Inc. and Vicente A. Rufino, its President.
    • Respondents: The Municipal Board of the City of Manila and Antonio Villegas, Mayor of the City of Manila (Respondent-Appellant).
    • The case is an action for declaratory relief to nullify Municipal Ordinance No. 4841 of the City of Manila.
  • Municipal Ordinance No. 4841 (December 31, 1963)
    • Enacted due to alleged scarcity of residential lands/buildings in Manila and a "state of emergency" in providing affordable housing.
    • Key provisions:
      • Section 1: Limits increases in rental of residential lands to a proportionate increase in assessed land value.
      • Section 2: Limits increases in rental of residential buildings to 10% per annum of the assessed value of building and land.
      • Section 3: Ordinance does not apply to existing leases at approval and to boarding/lodging houses but governs renewals/modifications after approval.
      • Section 4: Provides penalties (fine and imprisonment) for violations; legal persons held liable through responsible officers.
      • Section 5: Ordinance effective January 1, 1964.
  • Procedural History
    • The Court of First Instance of Manila declared the ordinance ultra vires, unconstitutional, illegal, and void ab initio.
    • No pronouncement as to costs.
    • The Mayor of Manila appealed the decision.
  • Grounds for Lower Court Decision
    • Exclusive power to declare a state of emergency rests with Congress.
    • Absence of a valid state of emergency to justify house rental regulation.
    • Ordinance imposes an unreasonable and unjustified limitation on private property use, infringing constitutional property rights.
    • The City’s power to regulate leasing/business does not extend to prohibiting rental increases as done by the ordinance.
    • Ordinance cannot be justified under the general welfare clause of the City Charter.

Issues:

  • Whether the City of Manila had the authority to declare a state of emergency and enact Municipal Ordinance No. 4841 regulating residential rentals.
  • Whether the ordinance is a valid exercise of the City’s police power or an unconstitutional encroachment on private property rights.
  • Whether an emergency ordinance regulating property rentals must have a definite and reasonable period of effectivity to be valid.
  • Whether failure to notify and hear the Solicitor General violated procedural rules, affecting the jurisdiction and validity of the proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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