Case Digest (G.R. No. 194575) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. L-7995, Lao H. Ichong, in his own behalf and on behalf of other alien residents, corporations, and partnerships adversely affected by Republic Act No. 1180, filed a petition on June 19, 1954, in the Supreme Court of the Philippines against Jaime Hernandez, Secretary of Finance, and Marcelino Sarmiento, City Treasurer of Manila. He sought a declaration that R.A. 1180, entitled “An Act to Regulate the Retail Business,” was unconstitutional and an injunction against its enforcement. The law effectively nationalized the retail trade by prohibiting non-citizens, and corporate entities not wholly owned by Filipinos, from engaging directly or indirectly in retail operations, subject to limited, time-bound, and death-contingent exceptions for aliens already in business. The Solicitor General and the Manila Fiscal answered, defending the Act as a valid exercise of the State’s police power, consistent with due process, equal protection, treaty obligations, and proper legislati Case Digest (G.R. No. 194575) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and parties
- Petitioner Lao H. Ichong, representing alien residents, corporations, and partnerships, challenged Republic Act No. 1180 (“Retail Trade Nationalization Act”) enacted June 19, 1954.
- Respondents: Jaime Hernandez (Secretary of Finance) and Marcelino Sarmiento (City Treasurer of Manila).
- Key provisions of RA 1180
- General prohibition of non-citizens and of associations, partnerships, or corporations not wholly Filipino-owned from engaging in retail trade; U.S. citizens excepted.
- Grandfather clauses allowing aliens engaged as of May 15, 1954 to continue until death or voluntary retirement (natural persons) and for ten years (juridical persons).
- Additional measures: automatic forfeiture of retail licenses for specified legal violations; ban on opening new stores or branches by excluded aliens; mandatory registration of existing businesses; six-month liquidation period for heirs of deceased aliens.
- Proceedings in the Supreme Court
- Petitioner sought a declaratory judgment declaring RA 1180 unconstitutional and an injunction against its enforcement.
- Grounds of attack: deprivation of liberty and property without due process; denial of equal protection; violation of the single-subject/title rule; infringement of international/treaty obligations; conflict with constitutional patrimony clauses.
- Government defended RA 1180 as a valid exercise of police power, consistent with the title, not breaching treaties, and respecting existing rights.
Issues:
- Constitutional validity under the Bill of Rights
- Does RA 1180 deprive alien residents and foreign-owned entities of liberty or property without due process?
- Does classification by citizenship deny equal protection of the laws?
- Title compliance
- Does the title “An Act to Regulate the Retail Business” conceal the true single subject of wholesale prohibition and nationalization?
- International and treaty obligations
- Does RA 1180 breach the United Nations Charter or the Universal Declaration of Human Rights?
- Does it violate the 1947 Treaty of Amity between the Philippines and the Republic of China?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)