Case Digest (G.R. No. L-23979)
Facts:
The case of Homeowners' Association of the Philippines, Inc. and Vicente A. Rufino vs. The Municipal Board of the City of Manila, et al., including Antonio Villegas, Mayor of the City of Manila arose from a legal challenge against Municipal Ordinance No. 4841 of Manila, approved on December 31, 1963, and taking effect on January 1, 1964. The ordinance aimed to regulate the rental rates of lots and buildings primarily for residential purposes within the city. It prohibited lessors or sublessors from increasing their rental fees above certain limits tied to the assessed value of the property. The ordinance was enacted under the premise of a declared state of emergency due to a scarcity of residential lands and buildings and the high cost of living, targeting reasonable housing accommodations particularly for the poor.
The Homeowners’ Association and its president, Vicente A. Rufino, filed for declaratory relief, claiming the ordinance was ultra vires, unconstitutional, illega
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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)