Title
Ermita-Malate Hotel and Motel Operators Association, Inc. vs. City Mayor of Manila
Case
G.R. No. L-24693
Decision Date
Jul 31, 1967
Hotel operators challenged Manila's Ordinance No. 4760, claiming it violated due process, privacy, and was oppressive. The Supreme Court upheld the ordinance as a valid exercise of police power to regulate public morals, ruling it reasonable and not arbitrary.

Case Summary (G.R. No. L-24693)

Petitioner Allegations and Relief Sought

Petitioners alleged Ordinance No. 4760 (enacted June 13, 1963; approved June 14, 1963) exceeded municipal powers and violated due process by (inter alia): imposing steep annual license fees (P6,000 for first-class motels; P4,500 for second-class), mandating public lobby registration forms capturing extensive personal data (including residence certificates and passport numbers) and subjecting premises to inspection by city officials, imposing minimum facility requirements for classified motels, prohibiting acceptance of persons under eighteen unless accompanied by parents/guardians, restricting rental of rooms to not more than twice in a 24-hour period, and providing for license cancellation upon subsequent conviction. They sought a writ of prohibition, a preliminary injunction (granted July 6, 1963), and a final judgment declaring the ordinance null and void.

Procedural History and Record

Respondent admitted factual circumstances, licensing status of petitioners, and the ordinance’s provisions but denied its invalidity. Rather than taking testimony, the parties filed a stipulation of facts (September 28, 1964) and submitted memoranda (respondent Jan. 22, 1965; petitioners Feb. 4, 1965). The lower court found the ordinance unconstitutional and made the preliminary injunction permanent. The appeal followed.

Applicable Law

Constitutional standard applied: due process principles under the constitution in force at the time (the pre-1987 constitution applicable to the 1967 decision). The case turned on the relationship between municipal police power and due process, and on established doctrines regarding presumption of constitutionality, municipal licensing authority, freedom of contract limitations, and vagueness challenges.

Principal Issue Presented

Whether Ordinance No. 4760 of the City of Manila violated due process (procedural or substantive) or otherwise was void on its face, thereby justifying the lower court’s declaration of unconstitutionality and the permanent injunction against enforcement.

Standard of Review and Presumption of Validity

The Court emphasized the strong presumption favoring the validity of legislative enactments, including municipal ordinances. When a statute or ordinance is challenged as unreasonable under the police power, factual foundations may condition constitutionality; where the record lacks evidentiary support to overthrow the presumption of validity, the presumption must prevail. Absent a showing that the ordinance is void on its face, courts should not lightly set aside legislative action.

Sufficiency of the Record

Because the parties submitted only a stipulation of facts and memoranda and offered no evidentiary proof to rebut the presumption of constitutionality, the appellate court held that the lower court erred in declaring the ordinance unconstitutional. The absence of a factual foundation in the record rendered the lower court’s sweeping condemnation unsupportable.

Purpose of the Ordinance and Police Power Analysis

The ordinance was enacted expressly to address perceived deterioration of public morals—an increased incidence of prostitution, adultery, and fornication associated with motels—and to deter clandestine uses of transient accommodations. The Court treated this legislative aim as plainly within the scope of the police power to promote public morals, health, safety, peace and general welfare. Given the explanatory note and the municipality’s assessment of an existing social problem, the ordinance was a legitimate police-power measure and not facially invalid.

License Fees and Municipal Discretion

The ordinance substantially increased annual license fees for hotels and motels. The Court reviewed established distinctions among license fees intended for regulation, for restricting non-useful occupations, and for revenue. Municipalities enjoy wide discretion in fixing fees—especially where the fee functions as a privilege tax or regulation over non-useful or morally regulated enterprises. Precedent affords considerable latitude to municipal authorities; mere disproportionality or hardship to existing businesses does not, by itself, render a license fee unconstitutional in the absence of demonstrative proof of arbitrariness or oppression.

Restriction on Leasing Frequency and Freedom of Contract

The ordinance’s prohibition on leasing a room more than twice every 24 hours was analyzed as a valid regulation incident to the police power. The Court rejected the contention that this restriction constituted an undue interference with liberty of contract. The opinion reiterated that liberty under democratic government is not license; the State may impose reasonable restraints on property and contractual freedom to protect public morals and welfare. Because the regulation corresponded to the municipal objective of preventing clandestine immoral use, the restriction was not arbitrary on its face.

Vagueness and Certainty Challenges

Petitioners argued certain provisions were vague (e.g., scope of “companions,” whether restaurant

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