White Light Corporations v.

City of Manila
GR No. 122846 (January 20, 2009)
TINGA, J.

Case Summary/Syllabi
Mayor Lim of Manila passed an ordinance which prohibited hotels, motels and other lodging
establishments from offering short time admission (stay for less than 12 hours) and wash up
rates (stay for only 3 hours), providing for a fine and imprisonment for violation of said
ordinance. Affected businesses filed a complaint to have the ordinance annulled, on the
ground that it was unconstitutional. The Court held in favor of the petitioners, ruling that the
ordinance failed the strict scrutiny test and was thus violative of substantial due process and
unconstitutional.

DOCTRINE
Although the goal of regulating public morals falls under the purview of police power, it does
not automatically justify any and all means of achieving this goal. The means must still align
with the Constitution, the Bill of Rights, and specifically due process. If the restriction
involves one restricting liberty, the Government must satisfy the strict scrutiny test: the
burden is on them to show that a) there is compelling State interest for the restriction; b) that
the means is necessary to address that compelling state interest, and c) that there is no other
alternative for the accomplishment of the purpose that is less intrusive.

Facts: On 3 Dec 1992, then Mayor Lim signed into law Ordinance No. 7774 entitled “An
Ordinance prohibiting short time admission in hotels, motels, lodging houses, pension houses
and similar establishments in the City of Manila”. White Light Corp is an operator of mini
hotels and motels who sought to have the Ordinance be nullified as the said Ordinance
infringes on the private rights of their patrons. The RTC ruled in favor of WLC. It ruled that
the Ordinance strikes at the personal liberty of the individual guaranteed by the Constitution.
The City maintains that the ordinance is valid as it is a valid exercise of police power. Under
the LGC, the City is empowered to regulate the establishment, operation and maintenance of
cafes, restaurants, beerhouses, hotels, motels, inns, pension houses, lodging houses and other
similar establishments, including tourist guides and transports. The CA ruled in favor of the
City.

Issue: Whether or not OrdinanceNo. 7774 is valid.

Ruling: The SC ruled that the said ordinance is null and void as it indeed infringes upon
individual liberty. It also violates the due process clause which serves as a guaranty for
protection against arbitrary regulation or seizure. The said ordinance invades private rights.
Note that not all who goes into motels and hotels for wash up rate are really there for obscene
purposes only. Some are tourists who needed rest or to “wash up” or to freshen up. Hence, the
infidelity sought to be avoided by the said ordinance is more or less subjected only to a
limited group of people. The SC reiterates that individual rights may be adversely affected
only to the extent that may fairly be required by the legitimate demands of public interest or
public welfare.