G.R. No. L-25601 - Vda. de Guison vs. Chief of the Philippine Constabulary

In 1960, the City Council of Quezon City enacted Ordinance No. 60-4346 pursuant to Section 80 of its Charter (Republic Act No. 537), authorizing cockfighting on Saturdays provided that the prescribed fees were paid and specific requirements complied with.
Petitioners, owners of the La Loma Cockpit, applied for and obtained a permit from the Quezon City Mayor to hold cockfights on Saturdays.
Subsequently, on August 10, 1964, the Quezon City Council enacted Ordinance No. 64-5990, which expanded the permissible dates for cockfighting to include not only Saturdays but also certain legal holidays and other weekdays upon payment of the prescribed fees.
The petitioners were granted a permit under this revised ordinance on March 11, 1965, to hold cockfights at the La Loma Cockpit on the specified dates.

On the morning of March 11, 1965, before any cockfighting took place, a Philippine Constabulary (PC) officer, acting on behalf of the PC Provincial Commander of Rizal, ordered the petitioners to desist, warning that failure to comply would result in a raid and closure of the cockpit.
Despite possessing the permit from the City Mayor, the petitioners, relying on their legal right under Ordinance No. 64-5990, refrained from holding the cockfights that day.
Previously, in Civil Case No. 6446, the Court of First Instance had rendered a judgment declaring Ordinance No. 60-4346 null and void (ultra vires), a decision that the respondents later argued barred the current proceedings.

On March 18, 1965, the petitioners filed a petition for injunction with the Court of First Instance of Rizal, Quezon City Branch, seeking to restrain the PC and its officers from interfering with the operations at the La Loma Cockpit on dates authorized by Ordinance No. 64-5990.
The respondents moved to dismiss the petition on two grounds:

That Ordinance No. 64-5990 was null and void, citing the precedent in Quimsing vs. Lachica.
That the action was barred by the earlier judgment in Civil Case No. 6446.

The trial court denied the motion to dismiss on April 4, 1965, issued a writ of preliminary injunction pending the filing of a bond, and later, on September 24, 1965, ordered the lifting of the preliminary injunction for lack of cause of action.
A stipulation of facts was submitted on July 14, 1965, which detailed:

The ownership of the La Loma Cockpit and the existence of permits and licenses issued by the City Mayor and the City Treasurer.
Evidence of compliance with municipal license fees, structural safety requirements, and sanitary standards as certified by relevant city departments.
The PC officer’s notice on March 11, 1965, and subsequent discussions indicating that cockfighting on certain weekdays was deemed illegal based on the Solicitor General’s opinion.
The absence of any written directive from the City Mayor to cease operations despite the issued permits.
The fact that petitioners were heirs to a previously litigated estate whose case had resulted in the nullification of Ordinance No. 60-4346.
An opinion rendered by the City Fiscal of Quezon City on January 7, 1965.

The petitioners sought judicial reconsideration of the order denying their petition, but the motion was denied on December 7, 1965.
The trial court stayed the lifting of the writ of preliminary injunction pending appeal, a stay that was later dissolved by the Court on July 25, 1966.
After the trial, several significant legal and political developments occurred:

The issuance of Proclamation 1081 on September 21, 1972, which placed the country under martial law.
The enactment of various Presidential Decrees (Nos. 421, 482, 531, 641, 765) integrating the police forces under the Philippine Constabulary.
The subsequent enactment of Presidential Decree No. 449 (the Cockfighting Law of 1974), which vested the supervisory authority over cockfighting with the Chief of the Philippine Constabulary.

That the trial court erred in not establishing that the respondents (PC officers) possessed no inherent police authority in Quezon City.
That the trial court erred in characterizing the respondents as the real parties in interest in challenging the validity of Ordinance No. 64-5990.
That the judgment in Civil Case No. 6446 barred the instant proceedings.
That the trial court erred in ruling that the petitioners had no cause of action.

Whether the respondents, as represented by the Philippine Constabulary, had the proper authority to interfere in the operations of the La Loma Cockpit within Quezon City given the exclusive allocation of police power to the City Mayor under the City Charter.
Whether the respondents were the proper parties with standing to question the validity of Ordinance No. 64-5990, or if such regulation was beyond their authority.
Whether the earlier judgment in Civil Case No. 6446, which declared Ordinance No. 60-4346 null and void, barred the current proceedings seeking injunctive relief.
Whether the petitioners, by virtue of holding permits issued under Ordinance No. 64-5990, established a valid cause of action against the interference by law enforcement.
Whether subsequent legislative enactments, particularly under martial law and the Cockfighting Law of 1974, rendered the issues moot and academic.