Ermita-Malate Hotel & Motel Operators Assoc., Inc vs Mayor of Manila
Police Power – Due Process Clause
On 13 June 1963, the Manila Municipal Board enacted Ord 4760 and the same was approved by then acting mayor Astorga. Ord 4760 sought to regulate hotels and motels. It classified them into 1st class (taxed at 6k/yr) and 2nd class (taxed at 4.5k/yr). It also compelled hotels/motels to get the demographics of anyone who checks in to their rooms. It compelled hotels/motels to have wide open spaces so as not to conceal the identity of their patrons. Ermita-Malate impugned the validity of the law averring that such is oppressive, arbitrary and against due process. The lower court as well as the appellate court ruled in favor of Ermita-Malate.
ISSUE: Whether or not Ord 4760 is against the due process clause.
HELD: The SC ruled in favor of Astorga. There is a presumption that the laws enacted by Congress (in this case Mun Board) is valid. W/o a showing or a strong foundation of invalidity, the presumption stays. As in this case, there was only a stipulation of facts and such cannot prevail over the presumption. Further, the ordinance is a valid exercise of Police Power. There is no question but that the challenged ordinance was precisely enacted to minimize certain practices hurtful to public morals. This is to minimize prostitution. The increase in taxes not only discourages hotels/motels in doing any business other than legal but also increases the revenue of the lgu concerned. And taxation is a valid exercise of police power as well. The due process contention is likewise untenable, due process has no exact definition but has reason as a standard. In this case, the precise reason why the ordinance was enacted was to curb down prostitution in the city which is reason enough and cannot be defeated by mere singling out of the provisions of the said ordinance alleged to be vague.