City of Manila v. Widow of Tan-Auco
REITERATIONFacts
The Antecedents: The City of Manila sought to collect P300 from the defendant, representing the second quarterly payment for a first-class liquor license issued to her for one year. Procedural History: The defendant refused to pay the installment, asserting she had ceased conducting the licensed business before the second quarter commenced. The lower court rendered a judgment absolving the defendant. The Appeal: The City of Manila appealed the decision, raising the legal issue of whether a yearly license obligation is a single, indivisible one, requiring full payment even if the business is discontinued before the year ends.
Issue(s)
Whether a first-class wholesale liquor license, issued for a period of one year, implies a single annual obligation to pay the total sum corresponding to the year, even if the business is not conducted for the entire period.
Ruling
The Supreme Court reversed the lower court's decision. It ruled that the defendant is obligated to pay the P300 demanded in the complaint, along with legal interest.
Ratio Decidendi
On the Issue of License Obligation: The Court held that a first-class wholesale liquor license, as provided for by Act No. 59 and amended by Act No. 95, creates a single, indivisible obligation to pay the full sum of P1,200 for the entire year. Act No. 95, which allowed for payment in four quarterly installments of P300 each, was interpreted not as a modification of the total obligation, but as a mere accommodation or facility for the licensee to meet the P1,200 requirement. The law clearly mandates that such licenses are issued for periods of one year and require payment in advance of the specified sum. Therefore, the licensee's cessation of business operations before the expiration of the license period does not extinguish her obligation to pay the full license fee for the entire year. The plaintiff is entitled to collect the outstanding quarterly installment.
Main Doctrine
The Court held that a first-class wholesale liquor license, issued for a period of one year under Act No. 59 and subsequently amended by Act No. 95, imposes a single, indivisible obligation to pay the full license fee of P1,200. Act No. 95, while allowing payment in four quarterly installments, did not alter the entirety of the obligation but merely provided a facility for payment. Therefore, a licensee who ceases to conduct business before the end of the license period remains liable for the full license fee.