Melchor, Jr. v. Moya
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the constitutionality of Republic Act No. 6359, also known as the Rent Control Law, and its subsequent amendment by Presidential Decree No. 20. The law was enacted to address a housing shortage and prevent unwarranted rental increases that prejudiced lower-income groups, aiming to promote public interest and general welfare by providing basic shelter rights. 2. Procedural History: The case originated from a decision by the Court of First Instance of Manila, presided over by respondent Judge Jose L. Moya, which declared Republic Act No. 6359 unconstitutional. This ruling was based on the ground that the Act did not constitute a valid exercise of police power. The Executive Secretary, Alejandro Melchor, Jr., subsequently filed a petition for certiorari by way of appeal to challenge this adverse decision. 3. The Petition: The petitioner, Executive Secretary Alejandro Melchor, Jr., seeks the reversal of the lower court's decision. The petition argues that Presidential Decree No. 20, which amended Republic Act No. 6359, is part of the law of the land under the Transitory Provisions of the Constitution. The petition further contends that the Rent Control Law is a valid police power measure, citing previous Supreme Court rulings that upheld similar legislation against challenges based on equal protection and substantive due process. The arguments emphasize the broad scope of police power and the presumption of validity afforded to legislative enactments, especially those that have undergone thorough deliberation.
Issue(s)
Whether Presidential Decree No. 20, amending Republic Act No. 6359, is a valid police power measure. Whether Republic Act No. 6359, as amended by Presidential Decree No. 20, violates substantive due process. Whether Republic Act No. 6359, as amended by Presidential Decree No. 20, violates the equal protection clause. Whether Presidential Decree No. 20, being a police power legislation, is applicable to leases entered into prior to its effectivity.
Ruling
The appealed decision declaring Republic Act No. 6359 unconstitutional is reversed. Costs are against respondents Realty Owners Association of the Philippines and Alberto Guevara, Sr.
Ratio Decidendi
On the validity of Presidential Decree No. 20 as a police power measure: The Court held that Presidential Decree No. 20, which amended Republic Act No. 6359, is part of the law of the land by virtue of Article XVII, Section 3, paragraph (2) of the Constitution. This provision explicitly states that Presidential Decrees promulgated by President Ferdinand E. Marcos shall remain valid, legal, binding, and effective unless modified, revoked, or suspended by him or expressly modified or repealed by the Batasang Pambansa. The Court cited Aquino, Jr. v. Commission on Elections and Gutierrez v. Cantada to reinforce the binding force of such decrees and legislation enacted under police power. The objective of the Rent Control Law, to remedy the plight of lessees and address a housing shortage, was recognized as a legitimate exercise of police power for the public interest and general welfare. On the alleged violation of substantive due process: The Court found no merit in the claim that the Rent Control Law lacked substantive due process. The Court characterized due process as the antithesis of arbitrary or capricious governmental acts and a guaranty of justice. It emphasized that a measure designed to ease a housing shortage and prevent unwarranted rental increases, which would prejudice lower-income groups, cannot be considered arbitrary or oppressive. The Court noted that shelter is a basic social and economic right, and the State is not compelled to remain inactive while a segment of its citizens suffers economic distress. The presumption of validity of legislative enactments, especially those that have undergone extensive deliberation, further supports this conclusion. On the alleged violation of the equal protection clause: While the objection in Gutierrez v. Cantada was based on equal protection, the Court here distinguished it from the present case's reliance on substantive due process. However, it reiterated the reasoning from Gutierrez that a police power measure intended to remedy the deplorable situation of lessees cannot be stigmatized as class legislation. The statute was enacted to promote public interest and general welfare, addressing a clear need arising from economic distress among a considerable segment of the citizenry. The broad and expansive scope of police power, encompassing the inherent powers of government, was invoked. On the applicability of Presidential Decree No. 20 to existing leases: The Court affirmed that police power legislation, being remedial in character, covers existing situations and that its applicability to existing contracts cannot be denied. Citing Pangasinan Transportation Co. v. Public Service Commission, Ongsiako v. Gamboa, and Abe v. Foster Wheeler Corp., the Court held that police power measures are superior to the constitutional guaranty of non-impairment of contracts when exercised in the interest of public health, safety, morals, and general welfare. Presidential Decree No. 20, as an amendment to Republic Act No. 6359, was intended to provide immediate relief and was thus applicable to leases entered into prior to its effectivity, preventing the Rent Control Law from being self-defeating. The Court also noted exceptions for humanitarian reasons, as in Sinclair v. Court of Appeals.
Main Doctrine
Presidential Decrees issued under the Transitory Provisions of the Constitution, such as Presidential Decree No. 20 amending Republic Act No. 6359 (Rent Control Law), are part of the law of the land and possess constitutional sanction, remaining valid and binding unless modified or repealed. Such police power measures, enacted to promote public interest and general welfare by addressing economic distress and housing shortages, are presumed valid and do not violate substantive due process or equal protection, even when applied to existing contracts, as the exercise of police power is superior to the non-impairment clause.