G.R. No. 200403 . October 10, 2022.
MUNICIPALITY OF BIÑAN, LAGUNA, ROGELIO V. LEE, ANTONIO P. AGUILAR AND ROBERTO HERNANDEZ, PETITIONERS, VS. HOLIDAY HILLS STOCK & BREEDING FARM CORPORATION AND DOMINO FARMS, INC., RESPONDENTS.

FACTS

The Municipal Council of Biñan, Laguna enacted Municipal Ordinance No. 06, series of 2004, which regulated urban control zones for agricultural use and mandated the gradual phase-out of large livestock farms, defined as those with more than ten swine or five hundred birds, within three years from its approval. The ordinance prohibited the issuance of new business permits for such farms and barred the renewal of permits for existing farms after the three-year period. Respondents Holiday Hills Stock & Breeding Farm Corporation and Domino Farms, Inc., operating large hog farms, received notice of the ordinance and subsequently filed a petition before the Regional Trial Court (RTC) assailing its validity. They argued that the ordinance was vague, arbitrary, and violated their constitutional right to due process.
The RTC dismissed the petition, upholding the ordinance as a valid exercise of police power, characterizing the hog farms as a nuisance per se due to their proximity to residential subdivisions. On appeal, the Court of Appeals (CA) reversed the RTC. While finding the ordinance not vague and not violative of property rights, the CA ruled it violated substantive due process. The appellate court held that the farms constituted a nuisance per accidens (a nuisance due to circumstances) rather than a nuisance per se (a nuisance by nature), and thus could not be abated summarily via a general ordinance without specific evidence of harm or a proper administrative proceeding.

ISSUE

Whether Municipal Ordinance No. 06 is a valid exercise of police power and does not violate the respondents’ right to substantive due process.

RULING

The Supreme Court GRANTED the petition, REVERSED the CA decision, and upheld the validity of Municipal Ordinance No. 06. The Court applied the established tests for a valid ordinance, requiring it to be within corporate powers, enacted following proper procedure, and conforming to substantive requirements: it must not contravene the Constitution or statute, must be fair and not oppressive, must be general and consistent with public policy, and must not be unreasonable.
The Court found the ordinance a legitimate exercise of police power under the general welfare clause of the Local Government Code. It was enacted to promote health, safety, and the comfort and convenience of Biñan’s inhabitants, legitimate objectives within the municipality’s delegated powers. The ordinance was not unreasonable; it provided a three-year grace period for existing farms to wind down operations, demonstrating a reasonable balance between public welfare and private interests. The Court rejected the CA’s rigid nuisance classification, emphasizing that the determination of what constitutes a nuisance and the necessary measures for its abatement is primarily a legislative function, especially when addressing potential public health hazards and urban planning concerns. The Sanggunian‘s judgment on the need to regulate livestock farms within urbanizing zones was accorded great respect, and the respondents failed to prove the ordinance was capricious or devoid of a rational basis. Consequently, the ordinance satisfied substantive due process as it was reasonably related to a lawful public purpose and employed lawful means.