FINAL EXAMINATION JOSEPH VALLECER

 

FINAL EXAMINATION IN POLITICAL LAW

January 16, 2021

 

Joseph P. Vallecer, JD-1

 

Andres Bonifacio College, SY- 2020-2021

 

 

1. Section 21 defines the procedure to be followed by the apprehending officers to ensure the integrity of the seized dangerous drugs and drug paraphernalia. State in your own understanding the procedure to be followed and the consequence of not following the said procedure.

 

Answer: Section 21 of R.A. No. 9165 requires that the seized items are physically inventory and be photographed in the presence of the accused or the persons from whom such items which were confiscated or seized, or his/her representative or counsel, a representative each from media and DOJ, and any elected public officials who shall be required to sign the copies of the inventory and be given a copy thereof. The record of these cases, however, were bereft of any showing of any showing of these photographs while the testimony of the prosecution witnesses was most notably silent on whether photographs were actually taken as required by law.

 

There is a Criminal Liability of a Public Officer or Employee for Misappropriation, Misapplication or Failure to Account for the Confiscated, Seized or Surrendered Dangerous Drugs, Plant Sources of Dangerous Drugs, Controlled Precursors and Essential Chemicals, Instruments/Paraphernalia and/or Laboratory Equipment Including the Proceeds or Properties Obtained from the Unlawful Act Committed. – The penalty of life imprisonment to death and a fine ranging from Five hundred thousand pesos (P500,000.00) to Ten million pesos (P10,000,000.00), in addition to absolute perpetual disqualification from any public office, shall be imposed upon any public officer or employee who misappropriates, misapplies or fails to account for confiscated, seized or surrendered dangerous drugs, plant sources of dangerous drugs, controlled precursors and essential chemicals, instruments/paraphernalia and/or laboratory equipment including the proceeds or properties obtained from the unlawful acts as provided for in this Act.

 

2. On July 7, 2008, 12 pastors and preachers from various churches filed a joint complaint-affidavit against the officers and publishers of seven men's magazines and tabloids. The complainants alleged that sometime during the period of September 2007 to July 2008, the identified magazines and tabloids, which were printed, published, distributed, circulated, and/or sold in the City of Manila, contained material which were "clearly scandalous, obscene, and pornographic within the meaning and in violation of Articles 200 and 201 of the Revised Penal Code and Ordinance No. 7780 of the City of Manila.

Questions

 

(A) The respondents claim that they cannot be charged under Article 200/201 and under the Manila Ordinance because they can be subjected to double jeopardy. Is this correct?

 

Answer: No, the respondents does not claim or invoked double jeopardy since the criminal case was already dismissed.

 

To raise the defense of double jeopardy, three requisites must be present: (1) a first jeopardy must have attached prior to the second; (2) the first jeopardy must have been validly terminated; and (3) the second jeopardy must be for the same offense as that in the first. In relation to this, the first jeopardy attaches only (a) upon a valid complaint or information, (b) before a competent court, (c) after arraignment and a valid plea has been entered; and (d) the accused was previously acquitted, convicted or the case was dismissed or otherwise terminated without his express consent.

 

 

(B) They also question the unconstitutionality of said ordinance. Is the said ordinance unconstitutional? What are the requisites for an ordinance to be valid?

 

Answer: Yes, no law shall be passed abridging the freedom of speech, of expression, or of the press, or the right of the people peaceably to assemble and petition the government for redress of grievances.

 

In order for an ordinance to be valid in substance, it (1) must not contravene the Constitution or any statute; (2) must not be unfair or oppressive; (3) must not be partial or discriminatory; (4) must not prohibit, but may regulate trade; (5) must be general and consistent with public policy; and (6) must not be unreasonable.

 

(C) Despite the dismissal of the charge for violation of Ordinance No. 7780, petitioners did not move to withdraw the present action, adamant that the Ordinance "violates the constitutional guarantees to free speech and expression, violates the right to due process, and offends privacy rights." On April 26, 2016 and upon petitioners' motion, Criminal Case No. 13-30084 was ordered dismissed with prejudice. The petition was dismissed on what grounds? Explain each ground.

 

Answer:  The petition on the following grounds for the dismissal:

(1) The dismissal of the criminal charges against petitioners for violation of the provisions of Ordinance No. 778014 has rendered this case moot and academic; and

(2) Ordinance No. 7780, an anti-obscenity law, cannot be facially attacked on the ground of overbreadth because obscenity is unprotected speech.

 

A moot and academic case is one that ceases to present a justiciable controversy by virtue of supervening events, so that a declaration thereon would be of no practical use or value. Generally, courts decline jurisdiction over such case or dismiss it on ground of mootness. This pronouncement traces its current roots from the express constitutional rule under paragraph 2 of Section 1, Article VIII of the 1987 Constitution that "judicial power includes the duty of the courts of justice to settle actual controversies involving rights which are legally demandable and enforceable." Judicial power, in other words, must be based on an actual justiciable controversy at whose core is the existence of a case involving rights which are legally demandable and enforceable. Without this feature, courts have no jurisdiction to act.

 

(D) Petitioners challenge the constitutionality of Ordinance No. 7780, alleging that it defines the terms "obscene" and "pornography" in such a way that a very broad range of speech and expression are placed beyond the protection of the Constitution, thus violating the constitutional guarantee to free speech and expression.Specifically, petitioners take issue with the "expansive" language of Ordinance No. 7780 which, petitioners claim, paved the way for complainants, a group of pastors and preachers, to impose their view of what is "unfit to be seen or heard" and "violate[s] the proprieties of language and behavior. Rule on said challenge. (5) In sum, the doctrines of strict scrutiny, overbreadth, and vagueness are analytical tools developed for testing "on their faces" statutes in free speech cases or, as they are called in American law, First Amendment cases. They cannot be made to do service when what is involved is a criminal statute. With respect to such statute, the established rule is that "one to whom application of a statute is constitutional will not be heard to attack the statute on the ground that impliedly it might also be taken as applying to other persons or other situations in which its application might be unconstitutional. Explain this statement as applied in the Madrilejos case.

 

Answer: The overbreadth doctrine finds special and limited application only to free speech cases. The present petition does not involve a free speech case; it stemmed, rather, from an obscenity prosecution. As both this Court and the US Supreme Court have consistently held, obscenity is not protected speech. No court has recognized a fundamental right to create, sell, or distribute obscene material. Thus, a facial overbreadth challenge is improper as against an anti-obscenity statute.

 

3. Juan was seen handing an item to Maria along an alley. A police officer 10 meters away saw this and it being that Juan is a notorious drug pusher, he immediately arrested Juan and a charge of illegal pushing of shabu was filed against him. Juan denied the charge saying that he did not sell shabu, the evidence however showed that the item was really shabu. Question: If you were the defense counsel of Juan what grounds would you invoke under our constitution to acquit him from said charge? Explain.

 

Answer: If I were the counsel of Juan. I invoked the right of the accused under Article III, section 1 and section 12 paragraph 1 of our Constitution.

 

SECTION 1. No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws.

 

SECTION 12. (1) Any person under investigation for the commission of an offense shall have the right to be informed of his right to remain silent and to have competent and independent counsel preferably of his own choice. If the person cannot afford the services of counsel, he must be provided with one. These rights cannot be waived except in writing and in the presence of counsel.

 

4. Section 14, paragraph 4 of the Anti-Hazing Law,which provides that an accused's presence during a hazing is prima facie evidence of his or her participation, is being questions whether it violates constitutional presumption of innocence. The petitioners also say that said provision is a bill of attainder. Said provision in particular provides that that one's presence during the hazing is prima facie evidence of participation as a principal, unless proven to have prevented or to have promptly reported the punishable acts to law enforcement authorities if they can, without peril to their person or their family. Question: (a)Is the Anti-hazing law unconstitutional? Is it a bill of attainder? What is a bill of attainder? What do you mean by the term “constitutional presumption of innocence? Is the law violative of said presumption? (b) Petitioner claims that Sections 3 and 4 of the Anti-hazing Law are unconstitutional, as they would allow for the conviction of persons for a crime committed by others, in violation of the res inter alios acta rule. What is your understanding of the res inter alios acta rule? She also argues that these provisions violate Article III, Sections 1 and 19 of the Constitution for constituting a cruel and unusual punishment, as she was charged as a principal, and penalized with reclusion perpetua, for a non-bailable offense. What is a “cruel and unusual punishment”? Cite some examples.  Is reclusion perpetua as a punishment “cruel”? Explain as to how the Supreme Court ruled on said claims.

 

Answer: a) No, Legislative acts are presumed constitutional. To be declared unconstitutional, a statute or any of its provisions must be shown to have clearly and unmistakably breached the Constitution. Petitioner has failed to discharge her burden of overcoming the presumption of the constitutionality of Section 14 of the Anti-Hazing Law.  

 

Yes, it is a bill of attainder, because they are group of people who committed crime and bill of attainder encroaches on the courts' power to determine the guilt or innocence of the accused and to impose the corresponding penalty, violating the doctrine of separation of powers. 

 

Bill of Attainder refers to the act of declaring a group of people guilty of a crime, and punishing them for it, usually without a trial. Officials have used bills of attainder to strip individuals of everything from their property to their lives.

 

b. The rule on res inter alios acta provides that the rights of a party cannot be prejudiced by an act, declaration, or omission of another. Consequently, an extrajudicial confession is binding only on the confessant, is not admissible against his or her co-accused and is considered as hearsay against them. The reason for this rule is that:

 

      On a principle of good faith and mutual convenience, a man’s own acts are binding upon himself, and are evidence against him. So are his conduct and declarations. Yet it would not only be rightly inconvenient, but also manifestly unjust, that a man should be bound by the acts of mere unauthorized strangers; and if a party ought not to be bound by the acts of strangers, neither ought their acts or conduct be used as evidence against him” (HAROLD V. TAMARGO vs. ROMULO AWINGAN, et al. G.R. No. 177727, January 19, 2010, Third Division, Corona, J.).

 

The constitution directs that "Excessive fines shall not be imposed, nor cruel and unusual punishment inflicted." The prohibition of cruel and unusual punishments is generally aimed at the form or character of the punishment rather than its severity in respect of duration or amount. (G.R. No. 208162, January 07, 2020).

 

No, the Court has found that the penalty of life imprisonment or reclusion perpetua does not violate the prohibition. Even the death penalty in itself was not considered cruel, degrading, or inhuman.

 

Nonetheless, the Court has found that penalties like fines or imprisonment may be cruel, degrading, or inhuman when they are "flagrantly and plainly oppressive and wholly disproportionate to the nature of the offense as to shock the moral sense of the community."116 However, if the severe penalty has a legitimate purpose, then the punishment is proportionate and the prohibition is not violated. (G.R No. 130038, September 18, 2000, Lim vs. People).

 

5. Explain the following terms (a)“buy-bust”, (b)chain of custody rule ,(c) insulating witnesses (d) Sec. 5 and (e) Section 11 (f)  Strict Neutrality v. Benevolent Neutrality on religious freedom (g) Miller Test  on obscenity.

 

a) Buy-bust - a buy-bust operation is a form of entrapment, whereby a police agent disguised as a buyer of illegal drugs undertakes a sales transaction with a seller.

 

b) Chain of custody rule - means the duly recorded authorized movements and custody of seized drugs or controlled chemicals from the time of seizure/confiscation to receipt in the forensic laboratory, to safekeeping to presentation in court for destruction.

 

c)  Insulating witnesses - required by the law to be present serve a very critical role in drug buy bust operations, to ensure there is no planting of evidence.

 

d) SEC. 5. Sale, Trading, Administration, Dispensation, Delivery, Distribution and Transportation of Dangerous Drugs and/or Controlled Precursors and Essential Chemicals.

 

e) SEC. 11. Possession of Dangerous Drugs. – The penalty of life imprisonment to death and a fine ranging from Five hundred thousand pesos (P500,000.00) to Ten million pesos (P10,000,000.00) shall be imposed upon any person, who, unless authorized by law, shall possess any dangerous drug in the following quantities, regardless of the degree of purity thereof:

 

f) Strict neutrality the latter holds that government should base public policy solely on secular considerations, without regard to the religious consequences of its actions. While benevolent neutrality allows accommodation of religion under certain circumstances. Accommodations are government policies that take religion specifically into account not to promote the government’s favored form of religion, but to allow individuals and groups to exercise their religion without hindrance.

 

g) Miller Test- also called the three-prong obscenity test, the Miller test consists of three (3) parameters to determine whether or not a particular material is considered "obscene"; in consequence, if a material is considered obscene, then it can be the subject of government regulation without infringing on the author's freedom of speech and expression. Through these three (3) parameters, the Miller test aims to define into demonstrable criteria what may be properly considered as "obscene" under judicial standards, and in so doing, seeks to delimit the conceptual malleability of "obscenity."  

 

 

6. SECTION 1. Section 1 of Presidential Decree No. 1866, as amended, is hereby further amended to read as follows:

 

‘SECTION 1. Unlawful Manufacture, Sale, Acquisition, Disposition or Possession of Firearms or Ammunition or Instruments Used or Intended to be Used in the Manufacture of Firearms or Ammunition. — The penalty of prision correccional in its maximum period and a fine of not less than Fifteen thousand pesos (P15,000) shall be imposed upon any person who shall unlawfully manufacture, deal in, acquire, dispose, or possess any low powered firearm, such as rimfire handgun, .380 or .32 and other firearm of similar firepower, part of firearm, ammunition, or machinery, tool or instrument used or intended to be used in the manufacture of any firearm or ammunition: Provided, That no other crime was committed. Question: (1) An accused committed murder using an unlicensed firearm. He was charged of two offenses, one under the revised penal code for murder and the other under P.D. 1866. Will there be no double jeopardy in this situation? Can a court convict him for the said two offenses? (2) There is such principle as the Agote doctrine. What is this principle and how would you apply said principle in the case at bar? Explain.

 

Answer: No, there will no double jeopardy in the case at bar, held that separate offense of illegal possession of firearms and ammunition if there is another crime committed.

 

Answer: Agote doctrine held that Section 1 of Republic Act No. 8294 is express in its terms that a person may not be convicted for illegal possession of firearms if another crime was committed.

 

7. An Ordinance is passed "Prohibiting the catching, gathering, possessing, buying, selling and shipment of live marine coral dwelling aquatic organisms, to wit: 1. Family: Scaridae (Mameng), 2. Epinephelus Fasciatus (Suno) 3. Cromileptes altivelis (Panther or Senorita), lobster below 200 grams and spawning), 4. Tridacna Gigas (Taklobo), 5. Pinctada Margaretefera (Mother Pearl, Oysters, Giant Clams and other species), 6. Penaeus Monodon (Tiger Prawn-breeder size or mother), 7. Epinephelus Suillus (Loba or Green Grouper) and 8. Family: Balistidae (T[r]opical Aquarium Fishes) for a period of five (5) years in and coming from Palawan Waterspetitioners. Petitioners  contend that:

 

First, the Ordinances deprived them of due process of law, their livelihood, and unduly restricted them from the practice of their trade, in violation of Section 2, Article XII and Sections 2 and 7 of Article XIII of the 1987 Constitution.

 

Second, Office Order No. 23 contained no regulation nor condition under which the Mayor's permit could be granted or denied; in other words, the Mayor had the absolute authority to determine whether or not to issue the permit.

 

Third, as Ordinance No. 2 of the Province of Palawan "altogether prohibited the catching, gathering, possession, buying, selling and shipping of live marine coral dwelling organisms, without any distinction whether it was caught or gathered through lawful fishing method," the Ordinance took away the right of petitioners-fishermen to earn their livelihood in lawful ways; and insofar as petitioners-members of Airline Shippers Association are concerned, they were unduly prevented from pursuing their vocation and entering "into contracts which are proper, necessary, and essential to carry out their business endeavors to a successful conclusion."

 

Question: Is the ordinance valid or not? Discuss vis-à-vis the first, second and third contentions.

 

Answer: The ordinance is valid, stating that the issuance of the ordinance is well within LGUs’ powers under the local government code. The High Tribunal stated that “We commend the Sangguniang Panlungsod of the City of Puerto Princesa and Sangguniang Panlalawigan of the Province of Palawan for exercising the requisite political will to enact urgently needed legislation to protect and enhance the marine environment, thereby sharing in the herculean task of arresting the tide of ecological destruction.”

 

8. An Ordinance is passed, with the pertinent provisions: (1)All public lands within Baguio townsite which are occupied by squatters who are duly registered as such at the time of the promulgation of this Ordinance such public lands not designated by city and national authorities for public use, shall be considered as embraced and comprising a City Government Housing Project; PROVIDED, HOWEVER, That areas covered by Executive Orders or Presidential Proclamations but the city had made official representation for the lifting of such orders or proclamation shall be deemed to be part of the Baguio Townsite for the purposes of this ordinance;

 

Section 2.—Building permits shall have been deemed issued to all squatters as contemplated by this Ordinance, giving such squatters five years from the approval of this Ordinance to satisfactorily comply with city building specifications and payment of the corresponding city building permit fees;

Section 3.—All cases pending in court against squatters be dropped without prejudice to the full prosecution of all subsequent violations in relation to the provisions of existing city ordinances and/or resolutions.

 

Question: Is said ordinance valid? Explain.

 

Answer: The Ordinance is not valid. Under the law, no disposition thereof could be made by the City of Baguio without prior legislative authority. It is the fundamental principle that the state possesses plenary power in law to determine who shall be favored recipients of public domain, as well as under what terms such privilege may be granted not excluding the placing of obstacles in the way of exercising what otherwise would be ordinary acts of ownership. And the law has laid in the Director of Lands the power of exclusive control, administrations, disposition and alienation of public land that includes the survey, classification, lease, sale or any other form of concessions or disposition and management of the lands of public domains.

 

9. Aniceto G. Saludo, Jr. filed a complaint for damages against the American Express International, Inc. (AMEX) and/or its officers Ian T. Fish, Vice-President and Country Manager, and Dominic Mascrinas, Head of Operations, with the RTC of Maasin City, Southern Leyte. The case was raffled to Branch 25 of the said court.

The complaint alleged, inter alia, that plaintiff (herein petitioner Saludo) "is a Filipino citizen, of legal age, and a member of the House of Representatives and a resident of Ichon, Macrohon, Southern Leyte, Philippines." On the other hand, defendant (herein respondent AMEX, Inc.) "is a corporation doing business in the Philippines and engaged in providing credit and other credit facilities and allied services with office address at 4th floor, ACE Building, Rada Street, Legaspi Village, Makati City." The other defendants (herein respondents Fish and Mascrinas) are officers of respondent AMEX, and may be served with summons and other court processes at their office address.

 

The complaint's cause of action stemmed from the alleged wrongful dishonor of petitioner Saludo's AMEX credit card and the supplementary card issued to his daughter. The first dishonor happened when petitioner Saludo's daughter used her supplementary credit card to pay her purchases in the United States some time in April 2000. The second dishonor occurred when petitioner Saludo used his principal credit card to pay his account at the Hotel Okawa in Tokyo, Japan while he was there with other delegates from the Philippines to attend the Congressional Recognition in honor of Mr. Hiroshi Tanaka.

 

The dishonor of these AMEX credit cards were allegedly unjustified as they resulted from respondents' unilateral act of suspending petitioner Saludo's account for his failure to pay its balance covering the period of March 2000. Petitioner Saludo denied having received the corresponding statement of account. Further, he was allegedly wrongfully charged for late payment in June 2000. Subsequently, his credit card and its supplementary cards were canceled by respondents on July 20, 2000.

 

Petitioner Saludo claimed that he suffered great inconvenience, wounded feelings, mental anguish, embarrassment, humiliation and besmirched political and professional standing as a result of respondents' acts which were committed in gross and evident bad faith, and in wanton, reckless and oppressive manner. He thus prayed that respondents be adjudged to pay him, jointly and severally, actual, moral and exemplary damages, and attorney's fees.

In their answer, respondents specifically denied the allegations in the complaint. Further, they raised the affirmative defenses of lack of cause of action and improper venue. On the latter, respondents averred that the complaint should be dismissed on the ground that venue was improperly laid because none of the parties was a resident of Leyte. They alleged that respondents were not residents of Southern Leyte. Moreover, notwithstanding the claim in his complaint, petitioner Saludo was not allegedly a resident thereof as evidenced by the fact that his community tax certificate, which was presented when he executed the complaint's verification and certification of non-forum shopping, was issued at Pasay City. To buttress their contention, respondents pointed out that petitioner Saludo's complaint was prepared in Pasay City and signed by a lawyer of the said city. Respondents prayed for the dismissal of the complaint a quo.

 

Thereafter, respondents filed an Opposition to Ex-Parte Motion (to Set Case for Pre-Trial) and Motion for Preliminary Hearing (on Affirmative Defense of Improper Venue) to which petitioner Saludo filed his Comments and/or Objections to the Affirmative Defense of Improper Venue. He asserted that any allegation refuting his residency in Southern Leyte was baseless and unfounded considering that he was the congressman of the lone district thereof at the time of the filing of his complaint. He urged the court a quo to take judicial notice of this particular fact. As a member of Congress, he possessed all the qualifications prescribed by the Constitution including that of being a resident of his district. He was also a member of the Integrated Bar of the Philippines-Southern Leyte Chapter, and has been such ever since his admission to the Bar. His community tax certificate was issued at Pasay City only because he has an office thereat and the office messenger obtained the same in the said city. In any event, the community tax certificate is not determinative of one's residence.

 

In the Order dated September 10, 2001, the court a quo denied the affirmative defenses interposed by respondents. It found the allegations of the complaint sufficient to constitute a cause of action against respondents. The court a quo likewise denied respondents' affirmative defense that venue was improperly laid. It reasoned, thus:

 

x x x [T]he fact alone that the plaintiff at the time he filed the complaint was and still is, the incumbent Congressman of the Lone District of Southern Leyte with residence at Ichon, Macrohon, Southern Leyte, is enough to dispel any and all doubts about his actual residence. As a high-ranking government official of the province, his residence there can be taken judicial notice of. As such his personal, actual and physical habitation or his actual residence or place of abode can never be in some other place but in Ichon, Macrohon, Southern Leyte. It is correctly stated by the plaintiff, citing the case of Core v. Core, 100 Phil. 321 that, "residence, for purposes of fixing venue of an action, is synonymous with domicile. This is defined as the permanent home, the place to which, whenever absent for business or pleasure, one intends to return, and depends on the facts and circumstances, in the sense that they disclose intent. A person can have but one domicile at a time. A man can have but one domicile for one and the same purpose at any time, but he may have numerous places of residence. Venue could be at place of his residence.

 

Questions: IN THIS case what is the residence of Saludo? What is his domicile? In election cases, is there a difference between domicile and residence? EXPLAIN.

 

Answer: Pasay City the residence of Saludo, only because he has an office thereat and the office messenger obtained the same in the said city. In any event, the community tax certificate is not determinative of one's residence.

 

Answer: Ichon, Macrohon, Southern Leyte as his domicile, because his permanent home and as a member of Congress, he possessed all the qualifications prescribed by the Constitution including that of being a resident of his district. He was also a member of the Integrated Bar of the Philippines-Southern Leyte Chapter, and has been such ever since his admission to the Bar.

 

Residence – is a place you live for a time to do business and works while domicile is defined as the permanent home, the place to which, whenever absent for business or pleasure, one intends to return, and depends on the facts and circumstances, in the sense that they disclose intent. A person can have but one domicile at a time.

 

10. Two ordinances were passed by the Cagayan De Oro Council.

 

(1)AN ORDINANCE PROHIBITING THE ISSUANCE OF BUSINESS PERMIT AND CANCELLING EXISTING BUSINESS PERMIT TO ANY ESTABLISHMENT FOR THE USING AND ALLOWING TO BE USED ITS PREMISES OR PORTION THEREOF FOR THE OPERATION OF CASINO.

 

(2)AN ORDINANCE PROHIBITING THE OPERATION OF CASINO AND PROVIDING PENALTY FOR VIOLATION THEREFOR:

 

QUESTION: ARE THESE ORDINANCES VALID? Explain.

 

Answer: No, the ordinance is not valid, the tests of a valid ordinance are well established. A long line of decisions has held that to be valid, an ordinance must conform to the following substantive requirements:

 

1) It must not contravene the constitution or any statute.

 

2) It must not be unfair or oppressive.

 

3) It must not be partial or discriminatory.

 

4) It must not prohibit but may regulate trade.

 

5) It must be general and consistent with public policy.

 

6) It must not be unreasonable.

 

 

Casino gambling is authorized by P.D. 1869. This decree has the status of a statute that cannot be amended or nullified by a mere ordinance. Hence, it was not competent for the Sangguniang Panlungsod of Cagayan de Oro City to enact Ordinance No. 3353 prohibiting the use of buildings for the operation of a casino and Ordinance No. 3375-93 prohibiting the operation of casinos. For all their praiseworthy motives, these ordinances are contrary to P.D. 1869 and the public policy announced therein and are therefore ultra vires and void.

 

 

 

 

End of the Examination