Title
Tan Tiong Eng vs. City Mayor, Pasay
Case
G.R. No. L-20209
Decision Date
May 19, 1966
Provisions prohibiting Chinese citizens from working as laborers in a city market are upheld as valid to enforce the Anti-Dummy Law in the Philippines.
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Case Digest (G.R. No. L-20209)

Facts:

  • The case involves Tan Tiong Eng (alias Kuong Leong) and other Chinese veteran plaintiffs against the City Mayor of Pasay City and city officials.
  • In May 1962, the defendants ordered the plaintiffs to stop working as laborers in the Pasay City Market, citing Republic Act No. 37 and Department of Finance Circular No. 32.
  • The plaintiffs argued that these legal provisions were not applicable to them and violated their constitutional rights, rendering them void.
  • The defendants referenced Municipal Ordinance No. 33 (1948), which allowed only Filipino or U.S. citizens to be employed as helpers by market stallholders.
  • Initially, Judge Demetrio Encarnacion ruled in favor of the plaintiffs, but a new trial was granted upon the defendants' request.
  • Thirty-two Filipino stallholders intervened, claiming the plaintiffs were capitalists employing Filipinos.
  • Judge Emilio Rilloraza ruled against the plaintiffs, affirming their status as capitalists and upholding the law and ordinance.
  • The plaintiffs appealed to the Court of Appeals, which forwarded the case to the Supreme Court, focusing on the legality of Section 23 of Municipal Ordinance No. 33.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's judgment, declaring Section 23 of Municipal Ordinance No. 33 legal and valid.
  • The Court held that the plaintiffs, as Chinese citizens, could not claim the right to work as laborers in the market, as the ordinance...(Unlock)

Ratio:

  • The Supreme Court recognized the legislative intent of Republic Act No. 37, which prioritizes Filipino citizens in public market leasing and restricts alien involvement.
  • The lower court's finding that the plaintiffs were capitalists rather than mere laborers aligned with the law's policies.
  • Allowing the plaintiffs to work in the market would contradict the nationalization policy a...continue reading

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