G.R. No. 218406 - Philippine Constitution Association vs. Philippine Government

The Insular Government had long owned and maintained two slaughterhouses: one at Pandacan and another at Sisiman.
These facilities originally served dual purposes as quarantine stations and as slaughterhouses for imported cattle.
The permit for importing cattle for slaughter had lapsed in May 1930, as it was then believed that the local cattle industry could adequately meet domestic demand.

On April 1, 1930, the Director of Animal Industry, with the approval of the Secretary of Agriculture and Natural Resources, issued an administrative order converting the Pandacan slaughterhouse into a public slaughterhouse.
This conversion was intended to streamline operations and improve the distribution of services for the livestock industry.
The City of Manila, in contrast, maintained a separate slaughterhouse which generated significant revenue, charging higher slaughtering rates compared to those at Pandacan.

The Association, as suggested by its name, is composed of members engaged in livestock and meat-selling activities.
It sought to utilize the Pandacan slaughterhouse because the lower rates would decrease costs for its members whose cattle were privately owned.
The intent was for the Association to slaughter cattle in Pandacan and subsequently sell fresh meat and refrigerated beef in various licensed outlets such as public markets and stores within Manila.

On March 5, 1932, the City of Manila approved an ordinance amending section 995 of its Revised Ordinances to effectively prohibit the use of the Pandacan slaughterhouse for privately owned cattle.
Subsequent actions by city officials included an arbitrary refusal to issue licenses under sections 653 and 654 of the Revised Ordinances to the Association and its members.
This created a direct conflict between the municipal authorities of Manila and the policies instituted by the Insular Government regarding the management and operation of the Pandacan facility.

Due to the conflicting positions between the City of Manila and the Insular Government, both parties sought injunctive relief from the Court of First Instance of Manila.
The core issues revolved around:

Whether the City of Manila had the authority to prohibit the sale of meat from privately owned cattle slaughtered at a government-run facility.
Whether the City could enjoin the Insular Government from permitting the slaughter of such cattle in its established offerings.

Central to the dispute was the interpretation and application of Act No. 2758 (as amended by Act No. 3632), particularly sections 1 and 3, which governed the powers related to the establishment, operation, and utilization of government slaughterhouses and stock farms.

Section 1 of Act No. 2758 grants broad authority to the Secretary of Agriculture and Natural Resources, through the Bureau of Animal Industry, to establish and maintain breeding stations, slaughterhouses, and stock herds/farms.
Section 3 provides the Director of Agriculture (Animal Industry) with specific powers to order the slaughter or sale of animals for varied purposes and to generate a special reimbursable fund from such operations.
The contention by the City was that section 3 served as a limitation on section 1, a point which was critically examined in the case.

Whether the officers of the City of Manila were justified in preventing the Philippine Cooperative Livestock Association, or its members, from selling fresh meat or refrigerated beef derived from cattle slaughtered at the Pandacan government facility.
Whether the City of Manila had the legal authority, through its municipal ordinance, to enjoin the Insular Government from conducting or allowing the slaughter of privately owned cattle at the Pandacan Slaughterhouse or any similar facility operated by the Bureau of Animal Industry.

How Act No. 2758, as amended by Act No. 3632, particularly its sections 1 and 3, should be interpreted:

Whether section 3 is to be regarded as imposing a limitation on the powers granted in section 1, or rather as conferring additional authority.

The extent to which the administrative orders and established practices under the Insular Government’s supervision override the local ordinance imposed by the City of Manila.

Determining the hierarchy of authority between the Insular Government and the City of Manila with respect to the management and disposition of government property and facilities.
Whether the actions taken under the Insular Government’s policies render the city’s attempts at regulation and revenue protection invalid or arbitrary.