Case Digest (G.R. No. 111097) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mayor Pablo P. Magtajas & the City of Cagayan de Oro (petitioners) versus Pryce Properties Corporation, Inc. and Philippine Amusement and Gaming Corporation (respondents), the Supreme Court reviewed two municipal ordinances passed by the Sangguniang Panlungsod of Cagayan de Oro City in late 1992 and early 1993. In 1992, PAGCOR leased part of Pryce Properties’ Pryce Plaza Hotel and prepared to inaugurate a casino during the Christmas season. In response, on December 7, 1992, the City Council enacted Ordinance No. 3353, prohibiting the issuance of new business permits or the continuation of existing permits for any establishment used, in whole or in part, for casino operations. On January 4, 1993, it passed Ordinance No. 3375-93, outright prohibiting the operation of casinos and providing administrative fines, closure of the establishment, and imprisonment for violators. Pryce Properties, joined by PAGCOR as intervenor, challenged both ordinances before the Court of Appeals, in Case Digest (G.R. No. 111097) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- PAGCOR’s Expansion to Cagayan de Oro City
- In 1992, the Philippine Amusement and Gaming Corporation (PAGCOR), pursuant to P.D. 1869, decided to expand its casino operations to Cagayan de Oro City by leasing and renovating a portion of Pryce Properties Corporation’s Pryce Plaza Hotel.
- The announcement triggered strong opposition from civic organizations, religious groups, women’s and youth organizations, and city officials, who led demonstrations and denounced the project as inimical to public morals and welfare.
- Enactment of City Ordinances
- On December 7, 1992, the Sangguniang Panlungsod enacted Ordinance No. 3353, prohibiting issuance (and authorizing cancellation) of business permits for any establishment used wholly or partly for casino operations.
- On January 4, 1993, the same body passed Ordinance No. 3375-93, outright prohibiting casino operations within city limits and prescribing administrative fines, closure, and imprisonment for violators.
- Judicial Proceedings
- Pryce Properties Corporation filed a petition for prohibition in the Court of Appeals, joined by PAGCOR, challenging both ordinances as ultra vires, confiscatory, and in conflict with P.D. 1869 and the Local Government Code.
- On March 31, 1993, the Court of Appeals declared the ordinances invalid and issued the writ prayed for; its denial of reconsideration on July 13, 1993 led petitioners—Mayor Pablo P. Magtajas and the City of Cagayan de Oro—to elevate the case to the Supreme Court under Rule 45.
Issues:
- Scope of Local Government Police Power
- Does the Sangguniang Panlungsod have authority under Sections 16 and 458 of R.A. 7160 to prohibit the establishment and operation of a PAGCOR casino within its territorial jurisdiction?
- Should the phrase “gambling and other prohibited games of chance” in Section 458(a)(1)(v) be construed to include legally authorized casinos or only illegal gambling?
- Conflict with National Law and Policy
- Do Ordinance Nos. 3353 and 3375-93 effectively amend, repeal, or contravene P.D. 1869, which grants PAGCOR exclusive authority to operate casinos in the Philippines?
- Are the ordinances discriminatory or partial—targeting casinos while permitting other forms of legalized gambling (e.g., cockfighting) without a rational basis?
- Hierarchy of Legal Norms and Precedent
- Can a city ordinance override a valid presidential decree with the force of statute, or impair contractual obligations under PAGCOR’s lease?
- Was the Court of Appeals correct in declining to follow this Court’s earlier Basco v. PAGCOR decision?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)