G.R. No. L-35256 - Melchor Jr. vs. Moya

The case involves Alejandro Melchor, Jr., in his capacity as Executive Secretary, challenging the decision of Judge Jose L. Moya, who had declared Republic Act No. 6359 (the Rent Control Law) unconstitutional.
The controversy centers on the issuance of Presidential Decree No. 20, which amended RA 6359.
Judge Moya’s decision was premised on the ground that the amended law was not a valid exercise of police power under the Constitution.

The Transitory Provisions of the 1973 Constitution provide that Presidential Decrees remain “valid, legal, binding, and effective” unless modified, revoked, or expressly repealed.
The decision references earlier jurisprudence, including Aquino, Jr. v. Commission on Elections, which upheld the President’s power to issue decrees having the force and effect of law even after the Constitution took effect.
The appellate decision also relies on Gutierrez v. Cantada, underscoring the binding nature of both RA 6359 and the subsequent amendments via PD No. 20 as valid police power legislation.

The Rent Control Law, as amended by PD No. 20, was designed to remedy the plight of lessees, especially those from lower-income groups, by controlling unjust rental increases.
The law was enacted in response to significant housing shortages and economic distress, aiming to promote the public interest and general welfare.
The legislative process was exhaustive; despite dissenting opinions from several senators, Congress enacted the law after thorough discussion and deliberation, thereby solidifying its presumption of validity.

The decision by Judge Jose L. Moya in the lower court was appealed through a certiorari proceeding instituted by Alejandro Melchor, Jr.
The appellate court’s review incorporated principles of due process and equal protection, examining whether the legislative measure was arbitrary or oppressive.
The question of retroactivity and the application of police power to existing contracts were also raised, with reference to past cases such as Pangasinan Transportation Co. v. Public Service Commission and Ongsiako v. Gamboa.

Does Presidential Decree No. 20, as an amendment to RA 6359, constitute a bona fide exercise of police power under the Constitution?
Is the amended law valid and binding as part of the law of the land as provided by the Constitutional Transitory Provisions?

To what extent should the judiciary review and question the legislative findings and policy considerations embedded in police power measures?
Does the prior exhaustive legislative deliberation negate claims of arbitrariness or oppressiveness, particularly in terms of substantive due process?

Can the retroactive application of PD No. 20, which affects existing leases, be justified on humanitarian or public welfare grounds?
Does the amendment, which intervenes in existing contracts, contravene the constitutional guarantee against impairment of contractual obligations?