Case Digest (G.R. No. 122846) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In White Light Corporation v. City of Manila, G.R. No. 122846, decided on January 20, 2009 under the 1987 Constitution, petitioners White Light Corporation (WLC), Titanium Corporation (TC), and Sta. Mesa Tourist & Development Corporation (STDC) challenged Manila City Ordinance No. 7774 enacted December 3, 1992. The Ordinance prohibited “short-time admission,” “wash-up rates,” or renting rooms for less than twelve hours in hotels, motels, inns, lodging houses, pension houses, and similar establishments within Manila, imposing fines up to ₱5,000 or imprisonment of up to one year for violations. On December 15, 1992, Malate Tourist & Development Corporation (MTDC) filed a declaratory relief action with prayer for a writ of preliminary injunction before the Regional Trial Court (RTC) of Manila, Branch 9, to declare the Ordinance unconstitutional as it affected MTDC’s Victoria Court operation under P.D. No. 259. On December 21, 1992, WLC, TC, and STDC intervened; MTDC later withdrew. Case Digest (G.R. No. 122846) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment of Ordinance No. 7774
- Approved December 3, 1992 by Mayor Alfredo S. Lim of the City of Manila.
- Titled “An Ordinance Prohibiting Short-Time Admission, Short-Time Admission Rates, and Wash-Up Rate Schemes in Hotels, Motels, Inns, Lodging Houses, Pension Houses, and Similar Establishments in the City of Manila.”
- Provisions:
- Declaration of policy to protect public welfare, health, youth and morality.
- Definitions: “short-time admission” means renting rooms for less than 12 hours or more than twice a day.
- Prohibition of short-time, pro-rated (“wash-up”) rates.
- Penalties: up to ₱5,000 fine and/or one-year imprisonment; automatic cancellation of business license upon second conviction.
- Repealing clause and immediate effectivity.
- Judicial Proceedings
- December 15, 1992 – MTDC filed declaratory relief with prayer for TRO and preliminary injunction before RTC Manila Branch 9; alleged conflict with P.D. No. 259 authority for short-time rates.
- December 21, 1992 – White Light Corp., Titanium Corp., and Sta. Mesa Tourist & Dev’t Corp. intervened as petitioners.
- January 14 and February 8, 1993 – RTC issued TRO and preliminary injunction halting enforcement.
- October 20, 1993 – RTC declared Ordinance No. 7774 null and void; made injunction permanent.
- City of Manila appealed to Supreme Court; petition treated as certiorari and referred to Court of Appeals (CA), which on April 2005 reversed and upheld ordinance.
- Petitioners filed for review on certiorari under Rule 45 before the Supreme Court.
Issues:
- Standing
- Whether the petitioners have direct and personal interest to challenge the ordinance.
- Applicability of third-party standing and overbreadth doctrines to assert patrons’ equal protection and liberty rights.
- Constitutional Validity of Ordinance No. 7774
- Whether the ordinance, as an exercise of police power, violates substantive due process by infringing on the fundamental right to liberty and privacy.
- Whether it breaches equal protection by arbitrarily restraining business operations and patrons without a reasonable classification.
- Whether less restrictive means were available to achieve the ordinance’s objectives.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)