Case Digest (G.R. No. 132216)
Facts:
This case involves the petitioners Lucas V. Umali, Belen R. Tolentino, Nestor Lamtecson, and Raymundo O. Martinez, who filed a special civil action against the City of Naga and its City Treasurer. The case was initiated in the Court of First Instance of Camarines Sur, seeking a writ of preliminary injunction, a writ of prohibition to prevent the enforcement of a municipal ordinance raising market lot rentals, and a writ of mandamus compelling the respondents to accept rental payments consigned in court. The petitioners argue that the rental increase was excessive, unreasonable, oppressive, and hence unconstitutional, claiming that the municipal board of the City of Naga acted with grave abuse of discretion. Furthermore, they alleged that the ordinance violated the city charter's provision requiring ordinances to be passed at least ten days prior to their effectivity; the ordinance in question was enacted on December 31, 1948, and became effective the next day. The municipal boarCase Digest (G.R. No. 132216)
Facts:
- Parties and Nature of the Case
- Petitioners: Lucas V. Umali, Belen R. Tolentino, Nestor Lamtecson, and Raymundo O. Martinez (among others) initiated a special civil action.
- Respondents: The City of Naga and its City Treasurer, responsible for the enforcement of the contested ordinance.
- Relief Sought:
- Issuance of a writ of preliminary injunction and a writ of prohibition to enjoin the enforcement of the ordinance.
- Mandamus directing the respondents to accept deposited monies representing rental fees.
- Any other remedy deemed just and equitable, along with an award for costs.
- The Contested Ordinance
- Nature of the Ordinance:
- Enacted by the municipal board of the City of Naga under the authority of section 15, paragraph a, of Republic Act No. 305 (the city charter).
- Titled “An ordinance imposing municipal license taxes upon persons, firms, companies, and corporations engaged in business and/or occupations.”
- Contains a specific provision (Section 9) that outlines the schedule or rates of rentals for municipal land, including market premises along Igualdad, P. Prieto, General Luna, and Zamora streets.
- Timing and Procedure:
- Passed on December 31, 1948.
- Made effective the following day (January 1, 1949), as authorized by section 14 of the charter.
- Allegations and Claims by the Petitioners
- The increase in rentals was argued to be excessive, highly oppressive, unreasonable, and therefore unconstitutional.
- The petitioners maintained that the municipal board acted with grave abuse of discretion in enacting the new schedule of rentals.
- They contended that the ordinance was passed in violation of the city charter’s requirement on the notice period, which mandates that an ordinance must be passed ten days before it becomes effective.
- Contentions and Supporting Evidence
- Comparison with Private Land Rentals:
- Petitioners contrasted the new rental rates of municipal properties with rentals charged by private owners nearby.
- Instances cited include rental amounts for various properties (e.g., buildings on General Luna and Zamora streets) demonstrating marked differences in the method and computation of rentals.
- Specific Data Presented:
- Rental increases for specific petitioners’ lots were enumerated:
- Lucas V. Umali’s lot of 40 sq.m. increased from P51 to P120.
- The Respondents’ Position
- Legality and Validity of the Ordinance:
- Asserted that the municipal board was properly empowered by the city charter to enact the ordinance.
- Defended the rental rates as reasonable, considering factors such as property improvements (paving, concrete, roofing with galvanized iron) and market conditions.
- Immediate Effectivity:
- Invoked section 14 of Republic Act No. 305 to justify the ordinance’s immediate effect from the day following its passage.
- Alternative Remedy:
- Argued that petitioners who had already paid their rentals (for January 1949) were estopped from questioning the ordinance's validity.
- Also maintained that petitioners had an alternative administrative remedy by appealing to the Secretary of the Interior for disapproval of the ordinance.
- Procedural History
- The City’s Court of First Instance (Camarines Sur) dismissed the petition, finding no ground to declare the ordinance unreasonable or oppressive.
- Costs were taxed against the petitioners, and only four of them appealed the decision.
Issues:
- Constitutionality and Reasonableness of the Rental Increase
- Whether the updated rental schedule, which significantly raised the rentals for market lots, is excessive, oppressive, and unreasonable.
- Whether the charge of abuse of discretion by the municipal board in setting these rental rates is justified.
- Validity of the Ordinance’s Passage and Its Immediate Effectivity
- Whether the ordinance was validly enacted within the framework provided by the city charter (Republic Act No. 305).
- Whether passing the ordinance on December 31, 1948, and making it effective the following day violates the charter’s procedural requirements (i.e., the ten-day notice rule).
- Jurisdiction and Adequacy of the Remedy
- Whether the petitioners have the proper remedy in pursuing a special civil action against the municipal board’s exercise of its taxing and rental rate determining powers.
- Whether the availability of an administrative remedy (via appeal to the Secretary of the Interior) renders the petition an inadequate mode of relief.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)