People v. Cruz
REITERATIONFacts
The Antecedents: The Municipality of Cabanatuan enacted Ordinance No. 4, series of 1928, which was later amended by Resolution No. 327. The amended ordinance prohibited the installation of any kind of engines within the MACHINERY ZONE, except for engines, machines, and apparatus used for "DELCO LIGHTS AND CINEMATOGRAPHS." The appellant, Maximo N. Cruz, was convicted of violating this ordinance. Procedural History: The Court of First Instance of Nueva Ecija convicted the appellant and sentenced him to pay a fine of P200, with subsidiary imprisonment in case of insolvency, and costs. The Petition: The appellant appealed the judgment, assigning several errors, primarily arguing that the ordinance was unconstitutional for being unjust, unreasonable, discriminatory, prohibitive of trade, and depriving him of equal protection of the laws. He also questioned the authority of the municipal council to enact such an ordinance and argued he was tried without due process.
Issue(s)
Whether Ordinance No. 4 of Cabanatuan, as amended, is unconstitutional for being unjust, unreasonable, discriminatory, prohibitive of trade, and depriving the accused of equal protection of the laws. Whether the municipal council of Cabanatuan exceeded its power in enacting the said ordinance. Whether the accused was tried and condemned without due process of law.
Ruling
The Supreme Court affirmed the judgment of the lower court, holding that the ordinance is valid and constitutional. The conviction of the appellant was sustained.
Ratio Decidendi
On the constitutionality of the ordinance and equal protection: The Court reiterated the established principle that municipal corporations may, in the exercise of their police power, enact ordinances on zonification. The ordinance in question was found to be within the powers granted to municipal councils under Section 2238 of the Revised Administrative Code. The Court clarified that the power to regulate, as granted by Section 2243(n) of the Revised Administrative Code, extends to motor engines, not just steam boilers, due to the progress of mechanical engineering and the inherent dangers of both types of engines. Furthermore, the ordinance does not prohibit engines but regulates their installation by means of zonification. The exception for "DELCO LIGHTS AND CINEMATOGRAPHS" was deemed a just and reasonable classification because the noise produced by engines for sawing wood differs significantly from the diversion provided by light and cinematograph machinery, thus not violating the right to equality before the law. On the authority of the municipal council: The appellant's contention that the municipal council was only authorized to regulate steam boilers and not motor engines was found untenable. The Court held that the authority granted under Section 2243(n) of the Revised Administrative Code should be construed to extend to motor engines, considering modern life and the similar dangerous nature and purpose of both types of engines. The power to regulate the installation of engines within a designated zone was considered within the scope of the council's authority. On due process: The Court addressed the claim of trial without due process, citing the case of McMicking vs. Schields to support the principle that a defendant is entitled to reasonable time to prepare a defense. However, the Court noted that it did not appear from the records that the defendant invoked his right under Section 30 of General Orders No. 58 to have at least two days for trial preparation after arraignment and plea. Therefore, this contention was deemed without merit.
Main Doctrine
Municipal councils, in the exercise of their police power, are empowered to enact zonification ordinances within their jurisdiction, and within the zones so established, they may determine the kinds of machinery to be installed therein, provided such classification is just and reasonable.