Case Digest (G.R. No. 225442) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Samahan ng mga Progresibong Kabatahan (SPARK), et al. v. Quezon City, City of Manila, and Navotas City, petitioners—SPARK, Joanne Rose Sace Lim, John Arvin Navarro Buenaagua, Ronel Baccutan, Mark Leo Delos Reyes, and minor Clarissa Joyce Villegas (represented by her father Julian Villegas, Jr.)—filed a petition for certiorari and prohibition directly with the Supreme Court on July 22, 2016. They sought a temporary restraining order to halt enforcement of three curfew ordinances targeting persons under eighteen: Navotas City’s Pambayang Ordinansa Blg. 99-02 (August 26, 1999) as amended by Ordinansa Blg. 2002-13 (June 6, 2002), City of Manila Ordinance No. 8046 (October 14, 2002), and Quezon City Ordinance No. SP-2301, Series of 2014 (July 31, 2014). Under “Oplan Rody,” local police strictly implemented these curfews from 10:00 p.m. (10:00 p.m.–4:00 a.m. in Manila; 10:00 p.m.–5:00 a.m. in Quezon City) to 3 a.m. in Navotas. Petitioners alleged the ordinances (a) are void for vag Case Digest (G.R. No. 225442) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Petitioners
- Samahan ng mga Progresibong Kabataan (SPARK), an association of youth and minors
- Individual petitioners: Joanne Rose Sace Lim, John Arvin Navarro Buenaagua, Ronel Baccutan, Mark Leo Delos Reyes, Clarissa Joyce Villegas (represented by her father)
- Respondents
- Quezon City, represented by Mayor Herbert Bautista
- City of Manila, represented by Mayor Joseph Estrada
- Navotas City, represented by Mayor John Rey Tiangco
- Curfew Ordinances Challenged
- Navotas City Ordinance Blg. 99-02 (Aug. 26, 1999) as amended by Blg. 2002-13 (Jun. 6, 2002) – juvenile curfew for under-18s
- City of Manila Ordinance No. 8046 (Oct. 14, 2002) – curfew 10 p.m. to 4 a.m.; prescribes reprimand, admonition, fines or imprisonment for violations
- Quezon City Ordinance No. SP-2301, Series 2014 (Jul. 31, 2014) – curfew 10 p.m. to 5 a.m.; penalties for parents/guardians
- Enforcement Context
- “Oplan Rody” operations – Metro Manila police implement curfews strictly
- Petitioners move for TRO, prohibition, and declaration of ordinances as ultra vires or unconstitutional
- Petitioners’ Contentions
- Void for vagueness – no clear enforcement standards, arbitrary arrests
- Overbreadth – prohibits legitimate minor activities at night
- Violates minors’ substantive due-process rights to liberty and travel
- Violates parents’ natural and primary right to rear their children
- Manila Ordinance penalties conflict with RA 9344 (Juvenile Justice and Welfare Act)
- Less restrictive alternatives exist (street lighting, CCTV, patrols, parental seminars)
Issues:
- Procedural Issues
- Propriety of certiorari/prohibition under Rule 65 to assail local ordinances
- Direct resort to the Supreme Court vs. hierarchy of courts
- Actual case or controversy; ripeness
- Standing of petitioners (individuals and SPARK)
- Substantive Issues
- Are the curfew ordinances void for vagueness (due-process concern)?
- Do the ordinances unconstitutionally infringe parents’ natural and primary right to rear their children?
- Do the ordinances unconstitutionally limit minors’ fundamental right to travel?
- Do the Manila Ordinance’s penal provisions conflict with RA 9344 (Sec. 57 and 57-A)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)