Case Digest (G.R. No. L-29646) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mayor Antonio J. Villegas v. Hiu Chiong Tsai Pao Ho (175 Phil. 443, En Banc, November 10, 1978), the Municipal Board of Manila enacted City Ordinance No. 6537 on February 22, 1968, which made it unlawful for any alien to be employed or engage in occupation in Manila without first securing a P50.00 employment permit from the Mayor. Exemptions applied only to diplomatic or consular personnel, technical assistance workers, household servants, and unpaid members of religious orders. Violations carried imprisonment of three to six months, a fine of P100.00 to P200.00, or both. On May 4, 1968, private respondent Hiu Chiong Tsai Pao Ho, an alien employed in Manila, filed Civil Case No. 72797 before the Court of First Instance of Manila, Branch I, seeking a writ of preliminary injunction and a declaratory judgment nullifying the ordinance on grounds that it (1) violated the rule on uniformity of taxation, (2) involved an unauthorized delegation of legislative power, and (3) infringed Case Digest (G.R. No. L-29646) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioner: Mayor Antonio J. Villegas, challenging the trial court’s decision in Civil Case No. 72797 granting injunctive and declaratory relief against City Ordinance No. 6537.
- Private respondent: Hiu Chiong Tsai Pao Ho, an alien employed in Manila, moved for a preliminary injunction and judgment declaring Ordinance No. 6537 null and void.
- Ordinance No. 6537
- Enactment: Passed by the Municipal Board of Manila on February 22, 1968; signed by Mayor Villegas on March 27, 1968.
- Substance:
- Prohibits aliens from employment or engaging in any business, trade, or occupation within Manila without securing an employment permit from the Mayor and paying a P50 fee.
- Exemptions: Diplomatic and consular personnel, technical assistance program participants, household workers of exempt persons, and uncompensated religious workers.
- Penalties: Imprisonment of 3–6 months, fine of P100–P200, or both, upon conviction.
- Trial Court Proceedings and Appeal
- May 4, 1968: Hiu Chiong Tsai Pao Ho filed Civil Case No. 72797 before the Court of First Instance of Manila, Branch I.
- May 24, 1968: Writ of preliminary injunction issued.
- September 17, 1968: Trial court permanently enjoined enforcement of Ordinance No. 6537 and declared it null and void.
- March 27, 1969: Mayor Villegas filed a petition for certiorari in the Supreme Court, assigning errors on the grounds of uniformity of taxation, undue delegation of legislative power, and violation of due process and equal protection.
Issues:
- Does Ordinance No. 6537 violate the constitutional rule on uniformity in taxation?
- Does the ordinance constitute an unlawful delegation of legislative power to the Mayor?
- Does the ordinance violate the due process and equal protection clauses of the Constitution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)