People v. Sabarre
REITERATIONFacts
The Antecedents: The defendants-appellants, Maria Vda. de Sabarre, Pedro Guy, and Tomas Basista, were charged with the violation of a municipal ordinance. Specifically, Article 1 of Ordinance No. 2, series of 1936, of the municipal council of Catarman, Samar, prohibited butchers and any other person from selling meat in any place except the public market. Article 2 prohibited fishermen or any other person from selling fresh fish and other commodities in the public streets of the poblacion. Procedural History: The Court of First Instance of Samar found the accused guilty beyond reasonable doubt of the violation of the municipal ordinance and sentenced each of them to pay a fine of five pesos (P5), with subsidiary imprisonment in case of insolvency, and one-third of the costs. The Petition: The defendants appealed the decision, assigning alleged errors of the court a quo, primarily questioning the constitutionality and validity of the municipal ordinance.
Issue(s)
Whether Ordinance No. 2, series of 1936 of Catarman, Samar, is unconstitutional for failing to express its subject in its title. Whether the ordinance is discriminatory, unreasonable, and oppressive for distinguishing between meat and fish vendors and requiring sales in an alleged unsanitary market. Whether defendants Pedro Guy and Tomas Basista were properly convicted for assisting in the sale of meat.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance of Samar in its entirety. The defendants-appellants were found guilty beyond reasonable doubt of the violation of the municipal ordinance and were sentenced to pay a fine of five pesos (P5) each, with subsidiary imprisonment in case of insolvency, and one-third of the costs.
Ratio Decidendi
On Issue 1: The Supreme Court (SC) ruled that the constitutional requirement that a bill embrace only one subject expressed in its title does not apply to municipal ordinances. Citing United States v. Espiritusanto, the Court explained that an ordinance is not a general law but a local regulation intended for the fulfillment of general laws. This principle, derived from the Act of Congress of July 1, 1902, remains applicable to the Article VI, Section 12 of the 1935 Constitution. Since ordinances do not partake of the nature of laws in the constitutional sense, it is not indispensable that their subject be expressed in the title. Consequently, the ordinance is not void for the alleged lack of a descriptive title. On Issue 2: The Court held that the ordinance is not discriminatory, unreasonable, or oppressive. The distinction between meat and fish vendors is valid because it is based on a substantial distinction regarding the susceptibility of these products to decay, especially when ice is unavailable. Following People v. Montil, the Court reaffirmed that municipal corporations may prohibit the sale of marketable articles outside established markets under their power to regulate and control such facilities. Regarding the claim that the market was muddy and unsanitary, the Court stated that the poor condition of the facility does not render the ordinance invalid. The citizens' remedy for the negligence of municipal officials in maintaining the market is to complain to higher authorities rather than violate the ordinance. On Issue 3: The Court found no error in the conviction of Pedro Guy and Tomas Basista. The evidence showed that these defendants did not merely slaughter the animals for their co-defendant Maria Vda. de Sabarre. They actively helped her in selling the meat outside the public market in violation of Article 1. Their direct participation in the acts prohibited by the ordinance makes them equally liable for the violation. Therefore, the lower court's finding of guilt beyond reasonable doubt for all three defendants was sustained by the record.
Main Doctrine
A municipal ordinance is not unconstitutional for failing to state its subject in the title, as this requirement applies only to general laws and not to local regulations. Furthermore, a classification in an ordinance is valid if it is based on substantial distinctions germane to the ordinance's purpose, not confined to existing conditions, and applies equally to all within its class. The unsanitary condition of a public market does not render an ordinance requiring its use oppressive if the municipality has the duty to maintain it and citizens have recourse against neglectful officials.