G.R. No. L-35256. March 17, 1983.
ALEJANDRO MELCHOR, JR., in his capacity as Executive Secretary, petitioner, vs. HON. JOSE L. MOYA, as Judge of the Court of First Instance of Manila, REALTY OWNERS ASSOCIATION OF THE PHILIPPINES, INC., and ALBERTO GUEVARA, SR., respondents.

FACTS

The petitioner, the Executive Secretary, sought the reversal of a decision by respondent Judge Jose L. Moya, which declared Republic Act No. 6359 (the Rent Control Law) unconstitutional. The lower court ruled that the law was not a valid exercise of police power. Subsequently, Presidential Decree No. 20 was issued, amending the said Rent Control Law. The case reached the Supreme Court via a certiorari proceeding by way of appeal from the adverse decision.

ISSUE

Whether Republic Act No. 6359, as a police power measure, is constitutional, particularly against the challenge that it violates substantive due process.

RULING

The Supreme Court reversed the decision of the respondent Judge and upheld the constitutionality of Republic Act No. 6359. The legal logic is anchored on several key principles. First, Presidential Decree No. 20, which amended the Rent Control Law, is explicitly recognized as part of the law of the land under the Transitory Provisions of the 1973 Constitution, having been promulgated by the President and remaining valid unless modified or repealed. This Court had previously upheld the President’s decree-making power in Aquino, Jr. v. Commission on Elections and affirmed the binding force of the Rent Control Law in Gutierrez v. Cantada.
Second, the law is a valid police power measure designed to address a critical housing shortage and protect lower-income groups from exorbitant rentals. The Court emphasized that police power is the state’s inherent authority to enact legislation for public welfare, and such measures are presumed constitutional. The standard for substantive due process is the absence of arbitrariness or oppressiveness. A law aimed at providing shelter, a basic social and economic right, cannot be deemed arbitrary. The legislative deliberation behind the Act further reinforces the presumption of its validity.
Third, the Court distinguished the challenge here (substantive due process) from an equal protection challenge resolved in Gutierrez, but the rationale for sustaining the law as a necessary socioeconomic measure remains compelling. The respondent Judge’s reliance on doubts expressed during Senate debates was misplaced, as the enactment of the law itself manifested legislative approval after thorough consideration. Finally, it would be illogical to declare the original statute unconstitutional while its amendatory decree (P.D. No. 20) remains in full force. The decision is reversed, with costs against the private respondents.