G.R. No. 38256 & 38257. December 16, 1933.

THE PHILIPPINE COOPERATIVE LIVESTOCK ASSOCIATION, petitioner-appellee, vs. TOMAS EARNSHAW, Mayor for the City of Manila, and VICTOR ALFONSO, City Treasurer, respondents-appellants.
THE CITY OF MANILA, petitioner-appellant, vs. THE PHILIPPINE COOPERATIVE LIVESTOCK ASSOCIATION, S. YOUNGBERG, in his capacity as Director of Animal Industry, NICOLAS SEVILLA, in his capacity as the Veterinarian in charge in the Pandacan Slaughterhouse, and JACINTO BAUTISTA as Foreman in said Pandacan Slaughterhouse, respondents-appellees.

FACTS

The Insular Government, through the Bureau of Animal Industry, owned and maintained the Pandacan Slaughterhouse. On April 1, 1930, the Director of Animal Industry issued an administrative order making it a public slaughterhouse. The City of Manila, by ordinance, later prohibited the use of the Pandacan Slaughterhouse for privately owned cattle and refused to grant the necessary meat-selling licenses to the Philippine Cooperative Livestock Association and its members, whose cattle were slaughtered there. This led to conflicting claims of authority between city and insular officials, resulting in cross-petitions for injunction in the trial court.

ISSUE

1. Can the City of Manila prohibit the sale of meat within its limits solely because the meat came from private cattle slaughtered at the Insular Slaughterhouse in Pandacan?
2. Can the City of Manila enjoin the Insular Government from slaughtering privately owned cattle in its slaughterhouses?

RULING

No to both issues. The Supreme Court affirmed the trial court’s decision.
1. The authority of the Insular Government, through the Bureau of Animal Industry, to establish and maintain slaughterhouses is derived from Act No. 2758 , as amended. Section 1 of the Act grants broad authority to establish and operate slaughterhouses. Section 3, which authorizes the disposal of government-owned animals, is an additional grant of power, not a limitation on the general authority in Section 1. Therefore, the Bureau could operate the Pandacan Slaughterhouse as a public facility for private cattle.
2. The City of Manila, as a creature of the Insular Government, cannot nullify the policy or action of the superior national authority. Its ordinances, even if framed as health measures, cannot be used to contravene the legitimate operations of an insular agency under a valid statute. The city’s attempt to prohibit the slaughter of private cattle at the insular slaughterhouse was an overreach of its authority.

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