**Facts:**
1. On November 24, 2004, the Municipal Council of Biñan, Laguna passed Municipal Resolution No. 284, approving Municipal Ordinance No. 06. This ordinance sought to regulate urban control zones for agricultural use by gradually phasing out large livestock farms in Biñan.
2. Under the Ordinance, livestock farms with over ten swine or five hundred birds were mandated to reduce their numbers within three years of the ordinance’s approval.
3. On April 6, 2005, the Sangguniang Panlalawigan of Laguna approved the ordinance.
4. On August 25, 2005, Holiday Hills Stock & Breeding Farm Corporation and Domino Farms, Inc. received notice that the ordinance was effective.
5. The farms filed a petition for Certiorari, Declaratory Relief, and Prohibition with the RTC on February 7, 2006, questioning the ordinance’s validity. They claimed it violated due process and was vague and unconstitutional.
6. The Municipality of Biñan and officials defended the ordinance, asserting their right to regulate using police powers.
7. On October 30, 2008, the RTC dismissed the farms’ petition, asserting that the ordinance was a valid exercise of police power and that the farms constituted a nuisance per se.
8. The farms appealed, and on August 22, 2011, the CA reversed the RTC’s decision, holding that while not vague, the ordinance violated due process as the farms were nuisances per accidens and couldn’t be abated summarily.
9. The MC filed a reconsideration motion, which was denied on January 26, 2012. They filed a petition for review to the Supreme Court.
**Issues:**
1. Whether the CA erred in reversing the RTC’s Decision and declaring Municipal Ordinance No. 06 invalid.
2. Whether Municipal Ordinance No. 06 violated the due process rights of the hog farms as it declared them a nuisance per se without judicial determination.
3. Whether the ordinance was a valid exercise of police power.
**Court’s Decision:**
1. **Validity of Municipal Ordinance No. 06:** The Supreme Court reversed the CA’s decision, upholding the ordinance. The Court held that it was within the powers of the Municipality to regulate under the guise of police power, referencing the general welfare clause.
2. **Due Process and Nuisance Classification:** The Supreme Court differed from the CA’s assessment, ruling that the hog farms were indeed nuisances per se because they emitted offensive odors, posing a direct threat to public health.
3. **Police Power:** The means used, which included regulating the livestock numbers, were neither unreasonable nor unduly oppressive to the farms. This fell within the ambit of reasonable regulation under municipal authority to protect public welfare, consistent with both statutory authority and principles of local government autonomy.
**Doctrine:**
This case reiterated the principle that municipalities have the power to enact ordinances under police power for the public’s welfare, provided these ordinances do not contravene the Constitution or state laws. Furthermore, nuisances can be summarily abated if they are nuisances per se, like conditions that immediately threaten community health or safety.
**Class Notes:**
– **Police Power:** Local government units, under Section 16 of the Local Government Code, can enact ordinances for public welfare, health, and safety.
– **Nuisance per se vs. Nuisance per accidens:** The former includes acts or conditions inherently harmful, warranting summary abatement.
– **Due Process:** Constitutional scrutiny requires that ordinances impacting property rights must be reasonable and substantially related to public interests.
**Historical Background:**
This case highlights the tension between economic activities, like large-scale farming, and urban residential growth. It reflects evolving municipal responsibilities in regulating business operations to protect community interests, especially concerning health and environmental standards within rapidly urbanizing areas. The decision underscores the strengthening of local governance powers under the Local Government Code, in the wake of increasing urbanization pressures.
Leave a Reply