People of the Philippines v. Juanito Solon

Juanito Solon was convicted and fined (with subsidiary imprisonment in case of insolvency) for having violated Cebu City Ordinance No. 241 (the Ordinance). The Ordinance required drivers of vehicle-drawing animals to properly dispose of the waste discharged by their vehicle-drawing animals while traveling City roads.

Solon challenged his conviction on the grounds that the Ordinance was invalid. He argued that the Ordinance violated the equal protection clause of the Constitution, because it applied only to owners and drivers of vehicle-drawing animals, rather than to all owners and possessors of animals equally. He also argued that the penalty of vehicle license suspension in the Ordinance constituted deprivation of property without just compensation.

The Court held that Ordinance No. 241 of the Municipal Board of Cebu City was constitutional. It considered that it was well established that the limited application of a statute did not necessarily violate the guarantee of equal protection of the laws, if the limitation was based on reasonable and not arbitrary or capricious criteria.

Here, the Ordinance was reasonable. It sought to promote the health and well-being of City residents, by eliminating animal waste in public areas. While the ordinance only applied to vehicle-drawing animals, this classification was reasonable because there were significantly more vehicle-drawing animals than other animals, and vehicle-drawing animals were therefore a greater health concern. Solon had not satisfactorily proved that the application of the Ordinance granted favors or imposed restrictions on owners of vehicle-drawing animals which were not accorded or enforced on others. As such, the Ordinance did not violate the constitutional prohibition against discriminatory legislation.

The Court also held that Solon could not bring a claim for deprivation of property without just compensation, as he did not own his vehicle and had not had his licence suspended.

“The principle is well-organized that the limited application of a statute, either in the objects to which it is directed or by the territory within which it is operate, does not necessarily violate the guaranty of ‘equal protection of the laws.’ It is sufficient, for purposes of complying with this constitutional mandate, that the classification be reasonable, not arbitrary or capricious.”

“In the case at bar, there is no doubt that the ordinance in question, seeking to eliminate animal wastes in the city streets and other public places, is a measure designed to promote the health and well-being of the residents. It is so stated in the ordinance. Admittedly, the same is directed only against vehicle-drawing animals passing through said places and thoroughfares. But it cannot be said that the classification is without reasonable basis.”