Case Summary (G.R. No. 34976)
Case Background
Seng Kee & Co., a commercial partnership, established a factory for producing toyo (soy sauce) under a license granted prior to the enactment of certain municipal ordinances. These ordinances subsequently classified the manufacture of toyo as a noxious industry that was restricted to designated industrial zones. Following complaints regarding the factory's operation, the City of Manila refused to renew Seng Kee's business license and ordered the relocation of the factory.
Ordinance Provisions
The Revised Ordinances divided the city into residential and industrial zones, declaring that certain trades, including the manufacture of toyo, could only be conducted in areas designated as industrial. Sections 1067 and 1068 specifically categorize the storage and production of toyo as offensive and unwholesome trades, thereby justifying restrictions on their operation based on public health and sanitation considerations.
Legal Issues
Seng Kee & Co. contested the constitutionality of the aforementioned sections, arguing that the ordinances deprived them of property without due compensation and exceeded the legislative powers of the City of Manila. The company's claims included assertions that they had always complied with health regulations, the classification of toyo as a noxious industry was erroneous, and that existing evidence was mishandled in court proceedings.
Findings and Judicial Reasoning
Classification as Noxious Industry: The court upheld the classification of toyo manufacturing as noxious based on health risks related to the fermentation process, as substantiated by expert testimony. The court noted the unsanitary conditions created by the factory's operations, which attracted pests and produced smoke, potentially causing harm to local residents.
Constitutionality of the Ordinances: The court emphasized the authority of the City of Manila to legislate zoning ordinances for public health and safety. The provisions in the ordinances were deemed a legitimate exercise of police power, designed to ensure proper sanitary conditions. The legislation restricts the use of property but does not constitute a taking of property or a violation of due process as it preserves ownership remains intact while regulating use.
Evidence and Procedural Challenges: The plaintiff's objections to the admission of evidence were found to be unfounded. The court affirmed that the introduction of complaints from residents was appropriate for demonstrating the necessity of regulatory actions taken by the Bureau of Health.
Failure to Prove Alleged Harm: The court determined that
Case Syllabus (G.R. No. 34976)
Case Overview
- The case centers on the validity and constitutionality of specific sections of the Revised Ordinances, No. 1600 of the City of Manila, particularly sections 120, 121, 122, 1067, and 1068, with a focus on the manufacture of the sauce known as toyo.
- Seng Kee & Co., a general commercial partnership, appealed a judgment from the Court of First Instance of Manila dated October 31, 1930, which upheld the ordinances' validity, dissolved a preliminary injunction, and dismissed the complaint, ordering costs against the appellant.
Background Information
- Seng Kee & Co. established a toyo factory in 1920, starting with a capital of P6,000, which later grew to P100,000, encompassing the factory's physical assets.
- The factory operated under licenses in compliance with previous ordinances until new ordinances classified certain trades, including toyo manufacturing, as noxious industries restricted to industrial zones.
- In 1924, following health complaints, the Bureau of Health advocated for the enactment of Ordinance No. 1287, which categorized the manufacture of toyo as a noxious industry.
Facts of the Case
- Following the enactment of the new ordinances, Seng Kee & Co. was denied a license to operate in its existing location and was instructed to relocate, which it contested, leading to this lawsuit.
- The manufacturing process of toyo involves fermenting salted gram and kidney beans, which, combined with treacle, attracts pests and p