Case Summary (G.R. No. L-23979)
Ordinance Subject to Judicial Review
The case involves Municipal Ordinance No. 4841 of the City of Manila, enacted on December 31, 1963, to take effect January 1, 1964. The ordinance sought to regulate rental increases for lands and buildings primarily used for residential purposes amid a declared "state of emergency" due to housing scarcity and high cost of living. It limited rental increases to a proportionate amount based on assessed land and building values and imposed penalties, including fines and imprisonment, for violations. Notably, the ordinance exempted existing leases but subjected renewals to its provisions.
Lower Court Ruling and Grounds for Invalidity
The Court of First Instance declared the ordinance ultra vires, unconstitutional, illegal, and void ab initio. The grounds included:
- The exclusive power to declare a state of emergency resides with Congress.
- There was no existing state of emergency justifying such regulation.
- The ordinance imposed an unreasonable and unjustifiable limitation on private property rights, encroaching on constitutional protections.
- The City of Manila lacked authority to regulate rent increases to the extent dictated by the ordinance.
- The general welfare clause in the City Charter does not authorize the ordinance’s provisions.
Supreme Court’s Approach to Constitutional Questions
The Supreme Court refrained from deciding whether the City had the power to declare a state of emergency or whether such a state existed. It emphasized that even assuming such powers and conditions, the ordinance remained illegal and unconstitutional due to the reasons explained in its opinion.
Legal Nature of Municipal Power and Constitutional Limitations
Municipal authority is primarily an exercise of police power, inherently involving some encroachment on individual liberties and property rights. As such, it must comply with constitutional safeguards and be reasonable. Regulations must be justified by legitimate public interest or welfare and proportionate to those demands. When enacted to address emergencies, such regulations must be coextensive in duration and scope with the emergency, acknowledging the inherently temporary character of emergencies.
Requirement of Temporality for Emergency Legislation
Citing domestic and foreign jurisprudence, the Court underscored the importance that emergency laws or ordinances have:
- A definite and reasonable time limitation linked to the nature and duration of the emergency.
- Avoidance of indefinite or permanent effects, as such would unlawfully convert temporary emergency measures into permanent law.
- Historical precedent in the Philippines showed that emergency powers or measures without fixed duration were held unconstitutional (e.g., moratorium laws and executive orders with no time limits).
Precedents on Emergency Powers and Police Power Limitations
The Court cited prior rulings rejecting statutes and executive orders that imposed indefinite restrictions on private rights, including monetary obligations or regulations beyond a reasonable emergency period. It emphasized that the framers of the Constitution intended that emergency powers be temporary and limited, influencing the requirement that laws or regulations arising from emergencies contain specific duration measures.
Application to the Ordinance in Question
The ordinance at issue contained no fixed time limitation, effectively making the rental restrictions indefinite. This indefinite application conflicted with the principle that emergency legislation must be limited in time. Consequently, even if the City possessed emergency powers, the ordinance's failure to provide a reasonable temporal boundary rendered it unconstitutional.
On the Requirement to Notify the Solicitor General
Appellant argued procedural irregularity due to the absence of notification and involvement of the Solicitor General, as required in actions questioning the constitutionality of laws under Section 4, Rule 64, of the Rules o
Case Syllabus (G.R. No. L-23979)
Factual and Procedural Background
- The case arose from a petition filed by the Homeowners' Association of the Philippines, Inc. and its President Vicente A. Rufino against the Municipal Board and the Mayor of the City of Manila.
- The petition sought declaratory relief to nullify Municipal Ordinance No. 4841 of the City of Manila.
- Ordinance No. 4841 was approved on December 31, 1963, and was set to take effect on January 1, 1964.
- The Ordinance regulated rentals of lots and buildings for residential purposes amidst a declared state of emergency due to scarcity of lands and high living costs.
- The Court of First Instance of Manila declared the ordinance ultra vires, unconstitutional, illegal, and void ab initio.
- The Mayor of Manila appealed the decision.
Content and Provisions of the Ordinance
- The ordinance declared a state of emergency to address the scarcity and high cost of residential accommodations.
- Section 1 prohibited lessors or sublessors from increasing rentals beyond the proportionate increase in assessed land value for residential lots or parts thereof.
- Section 2 prohibited increases in building rentals beyond 10% per annum of the assessed value of the building and land.
- Section 3 exempted existing lease contracts and boarding house rooms but subjected renewals or modifications after approval to the ordinance's provisions.
- Section 4 prescribed penalties for violations: fines ranging from P100 to P200 and imprisonment from one to six months, with liability extending to corporate officers in juridical persons.
- Section 5 confirmed the ordinance’s effectivity date as January 1, 1964.
Grounds for Invalidity as Held by the Lower Court
- The power to declare a state of emergency resides exclusively with Congress.
- No state of emergency existed to justify regulating house rentals at the time.
- The ordinance unreasonably limited the use of private property, infringing the constitutional rights of property owners.
- The City of Manila’s regulatory power over letting or subletting lands and buildings does not include prohibitions of the kind imposed by the ordinance.
- The general welfare clause in the City Charter did not sanction the ordinance.
Supreme Court’s Considerations on Police Power and Emergency Legislation
- Municipal authority to regulate constitutes an exercise of police power subject to constitutional limits protecting individual rights.
- Police power regulations must be reasonable and only affect individual rights as needed to meet legitimate public welfare demands.
- Emergency-based regulations must be coex