Eboña v. Municipality of Daet
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns Municipal Ordinance No. 7 of Daet, Province of Camarines Norte, enacted on June 12, 1948. This ordinance prescribed the zonification of the public market and established rules for occupying market spaces. Specifically, it designated Zone 1 for dry goods and general merchandise, Zone 2 for cafeterias and sari-sari stores, and Zone 3 for fresh fish, meat, and vegetables. Section 3 of the ordinance prohibited selling goods outside the allocated zones. Prior to this ordinance, the market had only two buildings, and the petitioners, operating cafeterias and sari-sari stores, were located in Building No. 1. 2. Procedural History: The petitioners challenged Municipal Ordinance No. 7, arguing it was unconstitutional, illegal, unjust, discriminatory, unreasonable, and confiscatory, particularly concerning their forced transfer from Market Building No. 1. They filed a complaint seeking a declaration of the ordinance's nullity and a permanent injunction against their eviction. The Court of First Instance of Camarines Norte upheld the ordinance's constitutionality and legality, finding it was enacted for the public good and within the municipal council's powers. Consequently, the court dismissed the petitioners' complaint. 3. The Petition: In their appeal to the Supreme Court, the plaintiffs-appellants reiterated their arguments assailing the constitutionality and legality of Municipal Ordinance No. 7. They also contended that they were entitled to continue occupying their stalls in accordance with Republic Act No. 37 and sought a perpetual injunction. The Supreme Court, however, found that Republic Act No. 37 was inapplicable as it pertains to the preference of Filipino citizens in market stall leases, an issue not raised. The Court affirmed the municipality's authority under the general welfare clause to enact such ordinances for public comfort and convenience, citing previous rulings that upheld similar market regulations as valid exercises of police power.
Issue(s)
Whether Municipal Ordinance No. 7 of Daet is unconstitutional, illegal, null, and void for being unjust, discriminatory, unreasonable, and confiscatory. Whether Republic Act No. 37 is applicable to the petitioners' situation.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, upholding the constitutionality and legality of Municipal Ordinance No. 7. The petition was dismissed, and the appellants were ordered to pay the costs.
Ratio Decidendi
On the constitutionality, legality, and reasonableness of Municipal Ordinance No. 7: The Court found that the municipal council of Daet was empowered to enact the ordinance under the general welfare clause of the Revised Administrative Code (Section 2238). This clause grants municipal councils the authority to enact necessary ordinances for the morals, peace, good order, comfort, and convenience of the municipality and its inhabitants. The Court held that Ordinance No. 7 provided for the good, comfort, and convenience of the public and market vendors by enabling consumers to easily locate desired goods and by placing vendors in appropriate zones. The Court cited Seng Kee & Co. vs. Earnshaw and U.S. vs. Salaveria, emphasizing that regulations, even if they interfere with an owner's desire for property use, are valid exercises of police power if not arbitrary or unreasonable. The Court also referenced Lorenzo and Estrella vs. Municipal Council of Naic, Cavite and Dinio, which affirmed the authority of municipalities to regulate market use and award spaces under imposed conditions. On the applicability of Republic Act No. 37: The Court found that Republic Act No. 37, which grants preference to Filipino citizens in the lease of public market stalls, was not applicable to the case. The issue of the nationality of the stallholders was not raised by the appellants, not mentioned in the ordinance, and the ordinance did not divest the appellants of their possession of the stalls. Therefore, the Act offered no assistance to their case.
Main Doctrine
Municipal councils are empowered under the general welfare clause to enact ordinances for the good, comfort, and convenience of the municipality and its inhabitants, including the regulation and zonification of public markets, provided such ordinances are not repugnant to law and are not arbitrary or unreasonable.