White Light Corp.

, vs City of Manila
Police Power Not Validly Exercised Infringement of Private Rights
On 3 Dec 1992, then Mayor Lim signed into law Ord 7774 entitled An Ordinance
prohibiting short time admission in hotels, motels, lodging houses, pension houses
and similar establishments in the City of Manila. White Light Corp is an operator of
mini hotels and motels who sought to have the Ordinance be nullified as the said
Ordinance infringes on the private rights of their patrons. The RTC ruled in favor of
WLC. It ruled that the Ordinance strikes at the personal liberty of the individual
guaranteed by the Constitution. The City maintains that the ordinance is valid as it
is a valid exercise of police power. Under the LGC, the City is empowered to regulate
the establishment, operation and maintenance of cafes, restaurants, beerhouses,
hotels, motels, inns, pension houses, lodging houses and other similar
establishments, including tourist guides and transports. The CA ruled in favor of the
City.
ISSUE: Whether or not Ord 7774 is valid.
HELD: The SC ruled that the said ordinance is null and void as it indeed infringes
upon individual liberty. It also violates the due process clause which serves as a
guaranty for protection against arbitrary regulation or seizure. The said ordinance
invades private rights. Note that not all who goes into motels and hotels for wash up
rate are really there for obscene purposes only. Some are tourists who needed rest
or to wash up or to freshen up. Hence, the infidelity sought to be avoided by the
said ordinance is more or less subjected only to a limited group of people. The SC
reiterates that individual rights may be adversely affected only to the extent that
may fairly be required by the legitimate demands of public interest or public
welfare.

Metropolitan Manila Development Authority vs.

Trackworks Rail Transit Advertising, Vending and
Promotions, Inc.
G.R. No. 179554

December 16, 2009

Petitioner: Metropolitan Manila Development Authority

Respondent: Trackworks Rail Transit Advertising, Vending and Promotions, Inc.
Facts: In 1997, the Government, through the Department of Transportation and
Communications, entered into a build-lease-transfer agreement (BLT agreement) with
Metro Rail Transit Corporation, Limited (MRTC) pursuant to Republic Act No. 6957
(Build, Operate and Transfer Law), under which MRTC undertook to build MRT3
subject to the condition that MRTC would own MRT3 for 25 years, upon the expiration
of which the ownership would transfer to the Government. In 1998, respondent
Trackworks Rail Transit Advertising, Vending & Promotions, Inc. (Trackworks) entered

into a contract for advertising services with MRTC. Trackworks thereafter installed
commercial billboards, signages and other advertising media in the different parts of the
MRT3. In 2001, however, MMDA requested Trackworks to dismantle the billboards,
signages and other advertising media pursuant to MMDA Regulation No. 96-009,
whereby MMDA prohibited the posting, installation and display of any kind or form of
billboards, signs, posters, streamers, in any part of the road, sidewalk, center island,
posts, trees, parks and open space. After Trackworks refused the request of MMDA,
MMDA proceeded to dismantle the formers billboards and similar forms of
advertisement.
Issue: Whether MMDA has the power to dismantle, remove or destroy the billboards,
signages and other advertising media installed by Trackworks on the interior and
exterior structures of the MRT3.
Ruling: That Trackworks derived its right to install its billboards, signages and other
advertising media in the MRT3 from MRTCs authority under the BLT agreement to
develop commercial premises in the MRT3 structure or to obtain advertising income
therefrom is no longer debatable. Under the BLT agreement, indeed, MRTC owned the
MRT3 for 25 years, upon the expiration of which MRTC would transfer ownership of the
MRT3 to the Government.
Considering that MRTC remained to be the owner of the MRT3 during the time material
to this case, and until this date, MRTCs entering into the contract for advertising
services with Trackworks was a valid exercise of ownership by the former. In fact,
in Metropolitan Manila Development Authority v. Trackworks Rail Transit
Advertising, Vending & Promotions, Inc., this Court expressly recognized Trackworks
right to install the billboards, signages and other advertising media pursuant to said
contract. The latters right should, therefore, be respected.
It is futile for MMDA to simply invoke its legal mandate to justify the dismantling of
Trackworks billboards, signages and other advertising media. MMDA simply had no
power on its own to dismantle, remove, or destroy the billboards, signages and other
advertising media installed on the MRT3 structure by Trackworks. In Metropolitan
Manila Development Authority v. Bel-Air Village Association, Inc., Metropolitan
Manila Development Authority v. Viron Transportation Co., Inc., and Metropolitan
Manila Development Authority v. Garin, the Court had the occasion to rule that
MMDAs powers were limited to the formulation, coordination, regulation,
implementation, preparation, management, monitoring, setting of policies, installing a
system, and administration. Nothing in Republic Act No. 7924 granted MMDA police
power, let alone legislative power.
The Court also agrees with the CAs ruling that MMDA Regulation No. 96-009 and
MMC Memorandum Circular No. 88-09 did not apply to Trackworks billboards,
signages and other advertising media. The prohibition against posting, installation and
display of billboards, signages and other advertising media applied only to public areas,
but MRT3, being private property pursuant to the BLT agreement between the
Government and MRTC, was not one of the areas as to which the prohibition applied.

Acebedo Optical Company, Inc. vs Court of Appeals

314 SCRA 315 Political Law Municipal Corporation Proprietary Functions Police
Power
Acebedo Optical Company, Inc. applied for a business permit to operate in Iligan
City. After hearing the sides of local optometrists, Mayor Camilo Cabili of Iligan
granted the permit but he attached various special conditions which basically made
Acebedo dependent upon prescriptions or limitations to be issued by local
optometrists. Acebedo basically is not allowed to practice optometry within the city
(but may sell glasses only). Acebedo however acquiesced to the said conditions and
operated under the permit. Later, Acebedo was charged for violating the said
conditions and was subsequently suspended from operating within Iligan. Acebedo
then assailed the validity of the attached conditions. The local optometrists argued
that Acebedo is estopped in assailing the said conditions because it acquiesced to
the same and that the imposition of the special conditions is a valid exercise of
police power; that such conditions were entered upon by the city in its proprietary
function hence the permit is actually a contract.
ISSUE: Whether or not the special conditions attached by the mayor is a valid
exercise of police power.
HELD: NO. Acebedo was applying for a business permit to operate its business and
not to practice optometry (the latter being within the jurisdiction PRC Board of
Optometry). The conditions attached by the mayor is ultra vires hence cannot be
given any legal application therefore estoppel does not apply. It is neither a valid
exercise of police power. Though the mayor can definitely impose conditions in the
granting of permits, he must base such conditions on law or ordinances otherwise
the conditions are ultra vires. Lastly, the granting of the license is not a contract, it
is a special privilege estoppel does not apply.
Association of Small Landowners in the Philippines, Inc. vs Secretary of Agrarian
Reform
175 SCRA 343 Political Law Constitutional Law Bill of Rights Equal Protection
Valid Classification
Eminent Domain Just Compensation
These are four consolidated cases questioning the constitutionality of the
Comprehensive Agrarian Reform Act (R.A. No. 6657 and related laws i.e., Agrarian
Land Reform Code or R.A. No. 3844).
Brief background: Article XIII of the Constitution on Social Justice and Human Rights
includes a call for the adoption by the State of an agrarian reform program. The
State shall, by law, undertake an agrarian reform program founded on the right of
farmers and regular farmworkers, who are landless, to own directly or collectively

the lands they till or, in the case of other farmworkers, to receive a just share of the
fruits thereof. RA 3844 was enacted in 1963. P.D. No. 27 was promulgated in 1972 to
provide for the compulsory acquisition of private lands for distribution among
tenant-farmers and to specify maximum retention limits for landowners. In 1987,
President Corazon Aquino issued E.O. No. 228, declaring full land ownership in favor
of the beneficiaries of PD 27 and providing for the valuation of still unvalued lands
covered by the decree as well as the manner of their payment. In 1987, P.P. No. 131,
instituting a comprehensive agrarian reform program (CARP) was enacted; later,
E.O. No. 229, providing the mechanics for its (PP131s) implementation, was also
enacted. Afterwhich is the enactment of R.A. No. 6657, Comprehensive Agrarian
Reform Law in 1988. This law, while considerably changing the earlier mentioned
enactments, nevertheless gives them suppletory effect insofar as they are not
inconsistent with its provisions.
[Two of the consolidated cases are discussed below]
G.R. No. 78742: (Association of Small Landowners vs Secretary)
The Association of Small Landowners in the Philippines, Inc. sought exception from
the land distribution scheme provided for in R.A. 6657. The Association is comprised
of landowners of ricelands and cornlands whose landholdings do not exceed 7
hectares. They invoke that since their landholdings are less than 7 hectares, they
should not be forced to distribute their land to their tenants under R.A. 6657 for
they themselves have shown willingness to till their own land. In short, they want to
be exempted from agrarian reform program because they claim to belong to a
different class.
G.R. No. 79777: (Manaay vs Juico)
Nicolas Manaay questioned the validity of the agrarian reform laws (PD 27, EO 228,
and 229) on the ground that these laws already valuated their lands for the agrarian
reform program and that the specific amount must be determined by the
Department of Agrarian Reform (DAR). Manaay averred that this violated the
principle in eminent domain which provides that only courts can determine just
compensation. This, for Manaay, also violated due process for under the
constitution, no property shall be taken for public use without just compensation.
Manaay also questioned the provision which states that landowners may be paid for
their land in bonds and not necessarily in cash. Manaay averred that just
compensation has always been in the form of money and not in bonds.
ISSUE:
1. Whether or not there was a violation of the equal protection clause.
2. Whether or not there is a violation of due process.

3. Whether or not just compensation, under the agrarian reform program, must be
in terms of cash.
HELD:
1. No. The Association had not shown any proof that they belong to a different class
exempt from the agrarian reform program. Under the law, classification has been
defined as the grouping of persons or things similar to each other in certain
particulars and different from each other in these same particulars. To be valid, it
must conform to the following requirements:
(1) it must be based on substantial distinctions;
(2) it must be germane to the purposes of the law;
(3) it must not be limited to existing conditions only; and
(4) it must apply equally to all the members of the class.
Equal protection simply means that all persons or things similarly situated must be
treated alike both as to the rights conferred and the liabilities imposed. The
Association have not shown that they belong to a different class and entitled to a
different treatment. The argument that not only landowners but also owners of
other properties must be made to share the burden of implementing land reform
must be rejected. There is a substantial distinction between these two classes of
owners that is clearly visible except to those who will not see. There is no need to
elaborate on this matter. In any event, the Congress is allowed a wide leeway in
providing for a valid classification. Its decision is accorded recognition and respect
by the courts of justice except only where its discretion is abused to the detriment
of the Bill of Rights. In the contrary, it appears that Congress is right in classifying
small landowners as part of the agrarian reform program.
2. No. It is true that the determination of just compensation is a power lodged in the
courts. However, there is no law which prohibits administrative bodies like the DAR
from determining just compensation. In fact, just compensation can be that amount
agreed upon by the landowner and the government even without judicial
intervention so long as both parties agree. The DAR can determine just
compensation through appraisers and if the landowner agrees, then judicial
intervention is not needed. What is contemplated by law however is that, the just
compensation determined by an administrative body is merely preliminary. If the
landowner does not agree with the finding of just compensation by an
administrative body, then it can go to court and the determination of the latter shall
be the final determination. This is even so provided by RA 6657:
Section 16 (f): Any party who disagrees with the decision may bring the matter to
the court of proper jurisdiction for final determination of just compensation.

3. No. Money as [sole] payment for just compensation is merely a concept in

traditional exercise of eminent domain. The agrarian reform program is a
revolutionary exercise of eminent domain. The program will require billions of pesos
in funds if all compensation have to be made in cash if everything is in cash, then
the government will not have sufficient money hence, bonds, and other securities,
i.e., shares of stocks, may be used for just compensation.