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GR 122846 White Light Vs City of Manila

1) Several hotel and motel operators in Manila filed a case challenging a city ordinance prohibiting short-time admissions in establishments like hotels and motels. 2) The issue is whether the establishments have legal standing to assert violations of their patrons' equal protection rights. 3) The court ruled that the establishments do have standing, as they meet the criteria of having a concrete interest affected by the ordinance, having a close relationship with patrons, and patrons facing hindrance in bringing their own case.

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245 views2 pages

GR 122846 White Light Vs City of Manila

1) Several hotel and motel operators in Manila filed a case challenging a city ordinance prohibiting short-time admissions in establishments like hotels and motels. 2) The issue is whether the establishments have legal standing to assert violations of their patrons' equal protection rights. 3) The court ruled that the establishments do have standing, as they meet the criteria of having a concrete interest affected by the ordinance, having a close relationship with patrons, and patrons facing hindrance in bringing their own case.

Uploaded by

Jimenez Lorenz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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G.R. No.

122846               January 20, 2009

WHITE LIGHT CORPORATION, TITANIUM CORPORATION and STA. MESA TOURIST &
DEVELOPMENT CORPORATION, Petitioners,
vs.
CITY OF MANILA, represented by DE CASTRO, MAYOR ALFREDO S. LIM, Respondent.

FACTS:
An Ordinance" prohibiting short time admission in hotels, motels, lodging houses, pension houses
and similar establishments in the City of Manila

Malate Tourist and Development Corporation (MTDC) filed a complaint to declare the ordinance
invalid and unconstitutional.

Petitioners White Light Corporation (WLC), Titanium Corporation (TC) and Sta. Mesa Tourist and
Development Corporation (STDC) filed a motion to intervene and to admit attached complaint-in-
intervention7 on the ground that the Ordinance directly affects their business interests as operators of
drive-in-hotels and motels in Manila.

Petitioners also allege that the equal protection rights of their clients are also being interfered with.

ISSUE:
The crux of the matter is whether or not these establishments have the requisite standing to plead
for protection of their patrons' equal protection rights.

RULING:

YES, the plaintiffs have the standing to plead for protection of their patrons’ equal protection rights.

In Powers v. Ohio,32 the United States Supreme Court wrote that: "We have recognized the right of
litigants to bring actions on behalf of third parties, provided three important criteria are satisfied:

1. The litigant must have suffered an ‘injury-in-fact,’ thus giving him or her a "sufficiently
concrete interest" in the outcome of the issue in dispute;
2. The litigant must have a close relation to the third party; and
3. There must exist some hindrance to the third party's ability to protect his or her own
interests.

ANALYSIS:

It is clear that the business interests of the petitioners are likewise injured by the Ordinance. They
rely on the patronage of their customers for their continued viability which appears to be threatened
by the enforcement of the Ordinance. The relative silence in constitutional litigation of such special
interest groups in our nation such as the American Civil Liberties Union in the United States may
also be construed as a hindrance for customers to bring suit.

Assuming arguendo that petitioners do not have a relationship with their patrons for the former to
assert the rights of the latter, the overbreadth doctrine comes into play. In overbreadth analysis,
challengers to government action are in effect permitted to raise the rights of third parties. Generally
applied to statutes infringing on the freedom of speech, the overbreadth doctrine applies when a
statute needlessly restrains even constitutionally guaranteed rights. In this case, the petitioners claim
that the Ordinance makes a sweeping intrusion into the right to liberty of their clients. We can see
that based on the allegations in the petition, the Ordinance suffers from overbreadth.

CONCLUSION:

The Court recognizes that the petitioners have a right to assert the constitutional rights of their
clients to patronize their establishments for a "wash-rate" time frame.

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