Title
City of Manila vs. Laguio, Jr.
Case
G.R. No. 118127
Decision Date
Apr 12, 2005
Manila's Ordinance No. 7783, banning motels in Ermita-Malate, was ruled unconstitutional for violating due process, equal protection, and exceeding police power limits.

Case Summary (G.R. No. L-23851)

Issue

Whether the City of Manila’s Ordinance 7783 is valid under the 1987 Constitution and applicable laws, or whether it is ultra vires, arbitrary, discriminatory, and unconstitutional.

Constitutional Framework and Police Power Limits

  • Police power delegations to local governments (Const. Art. II, Sec. 5; Art. III, Sec. 1; LGC Sec. 16) must be reasonable, non-arbitrary, and for public good.
  • Due process forbids arbitrary deprivation of life, liberty, or property; includes substantive and procedural safeguards.
  • Equal protection prohibits unjustifiable discrimination among similarly situated parties.
  • Just compensation clause (Art. III, Sec. 9) bars regulatory measures that effect a “taking” of property without indemnity.

Due Process Analysis

  • Ordinance imposes absolute prohibition—no intermediate regulation—on motels and other establishments, compelling winding up, transfer, or conversion within three months.
  • Such sweeping closure, without demonstrating that lesser restrictions (e.g., licensing conditions, inspections, revocations) would be inadequate, violates substantive due process.
  • Means bear no reasonable relation to the stated moral and social welfare aims: closing motels will not eradicate prostitution or illicit conduct, which may migrate to other venues.
  • Ordinance’s lack of clear standards for “disturbing the community” or “using women as tools” invites unchecked executive discretion—breaching procedural due process.

Equal Protection Analysis

  • Classification lumps motels and inns with inherently disreputable houses, yet exempts hotels, pension houses, lodging houses and similar establishments—no substantial distinction supports this divergence.
  • Prohibition limited to Ermita-Malate is arbitrary; illicit activities do not become less offensive if located elsewhere.
  • Gender-based language (“women used as tools”) discriminates without rational basis.

Consistency with General Laws and Ultra Vires Determination

  • Local Government Code grants City Council power to regulate, not prohibit, hotels, motels, inns, and similar businesses (Sec. 458(a)(4)(iv)).
  • Prohibitory authority under Sec. 458(a)(4)(vii) applies only to forms of entertainment and events “which tend to disturb the community” (e.g., public dancing, circuses), not to bona fide lodging businesses.
  • P.D. 499 expressly designates Ermita-Malate as commercial zone permitting all commercial establishments except a narrow class; ordinance conflicts with this national decree.
  • Revised Charter’s general welfare clause cannot override later, specific provisions of the Local Government Code; any inconsistency is deemed repealed by implication (LGC Sec. 534(f)).

Regulatory Taking and Just Compensation

  • Ordinance’s permanent closure and padlocking of violative premises “goes beyond regulation” and effectively co

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