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Republic of the Philippines

Saint Louis University


School of Law

Digested Cases in Constitutional Law II

Submitted to:

Atty. Jennifer N. Asuncion

Submitted by:

Gener, Francess Louise E.

Kido, Julie Bernadine T.

Perez, Crichelle R.

Ap-apid, Corriur A.

Larin, Christian John V.

Medrano, Mikhael V.

Motilla, Alvin D.
I. POLICE POWER
In the case of St. Luke's Medical Center Employee's Association-afw v.
NLRC, G.R. No. 162053, March 7, 2007, the court ruled that the enactment of R.A. (Nos.)
7431 or the Radtech Act Of 1992 and 4226 otherwise known as the Hospital Licensure Act
are recognized as an exercise of the State's inherent police power. It should be noted
that the police power embraces the power to prescribe regulations to promote the
health, morals, education, good order, safety or general welfare of the people. The state
is justified in prescribing the specific requirements for x-ray technicians and/or any other
professions connected with the health and safety of its citizens. Respondent-appellee
being engaged in the hospital and health care business, is a proper subject of the cited
law; thus, having in mind the legal requirements of these laws, the latter cannot close its
eyes and let complainant-appellant's private interest override public interest. The law is
clear that the Certificate of Registration cannot be substituted by any other requirement
to allow a person to practice as a Radiologic Technologist and/or X-ray Technologist.

In Professional Regulation Commission (PRC) v. De Guzman, G.R. No. 144681, June 21,
2004, this Court has upheld the constitutional right of every citizen to select a profession or
course of study subject to a fair, reasonable, and equitable admission and academic
requirements. But like all rights and freedoms guaranteed by the Charter, their exercise may
be so regulated pursuant to the police power of the State to safeguard health, morals,
peace, education, order, safety, and general welfare of the people. Thus, persons who desire
to engage in the learned professions requiring scientific or technical knowledge may be
required to take an examination as a prerequisite to engaging in their chosen careers. This
regulation assumes particular pertinence in the field of medicine, in order to protect the
public from the potentially deadly effects of incompetence and ignorance.

Note that in Chavez v. Romulo, G.R. No. 157036, June 9, 2004, the court ruled that laws
regulating the acquisition or possession of guns have frequently been upheld as reasonable
exercise of the police power. Just like ordinary licenses in other regulated fields, PTCFOR
may be revoked any time. It does not confer an absolute right, but only a personal privilege
to be exercised under existing restrictions. Revocation of it does not deprive the defendant
of any property, immunity, or privilege. The basis for its issuance was the need for peace and
order in the society. The assailed Guidelines do not entirely prohibit possession of firearms.
What they proscribe is merely the carrying of firearms outside of residence. However, those
who wish to carry their firearms outside of their residences may re-apply for a new PTCFOR.
This is a reasonable regulation. If the carrying of firearms is regulated, necessarily, crime
incidents will be curtailed.
In Metropolitan Manila Development Authority v. Garin, G.R. No. 130230, April 15,
2005, the court ruled that the MMDA does not have the power to confiscate, suspend or
revoke driver’s licenses without a traffic law or regulation validly enacted by the legislature
or those of the local government units to whom legislative powers have been delegated.
Once there is such a law, MMDA is duty-bound to confiscate, suspend or revoke drivers’
licenses in the exercise of its mandate of transport and traffic management. License to
operate a motor vehicle is not a property, but a privilege granted by the state which may be
suspended or revoked by the state in the exercise of its police power, in the interest of
public safety and welfare, subject to the procedural requirements of due process.

The MMDA is not vested with police power. It was concluded that MMDA is not a
local government unit of a public corporation endowed with legislative power and it has no
power to enact ordinances for the welfare of the community. Police power, as an inherent
attribute of sovereignty is the power vested in the legislature to make, ordain, establish all
manner of wholesome and reasonable laws, statutes and ordinances either with penalties or
without, not repugnant to the constitution, as they shall judge to be for good and welfare of
the commonwealth and for subjects of the same. There is no provision in RA 7924 that
empowers MMDA or its council to “enact ordinance, approve resolutions and appropriate
funds for the general welfare of the inhabitants of Metro Manila.” It is an agency created for
the purpose of laying down policies and coordinating with the various national government
agencies, People’s Organizations, NGOs and private sector for the efficient and expeditious
delivery of services. All its functions are administrative in nature.

In the case of Surigao Del Norte Electric Cooperative, Inc. (SURNECO) v.


Energy Regulatory Commission, G.R. No. 183626, October 4, 2010, the court ruled that the
regulation of rates to be charged by public utilities is founded upon the police powers of the
State and statutes prescribing rules for the control and regulation of public utilities are a
valid exercise thereof. When private property is used for a public purpose and is affected
with public interest, it ceases to be juris privati only and becomes subject to regulation. The
regulation is to promote the common good. Submission to regulation may be withdrawn by
the owner by discontinuing use; but as long as use of the property is continued, the same is
subject to public regulation. It has long been settled that police power legislation, adopted
by the State to promote the health, morals, peace, education, good order, safety, and
general welfare of the people prevail not only over future contracts but even over those
already in existence, for all private contracts must yield to the superior and legitimate
measures taken by the State to promote public welfare.
The Supreme Court held In Buklod Ng Magbubukid sa Lupaing Ramos, Inc. v. E. M.
Ramos And Sons, Inc., G.R. No. 131481, March 10, 2011, that by virtue of a zoning
ordinance, the local legislature may arrange, prescribe, define, and apportion the land within
its political jurisdiction into specific uses based not only on the present, but also on
the future projection of needs. To limit zoning to the existing character of the property and
the structures thereon would completely negate the power of the local legislature to plan
land use in its city or municipality. Under such circumstance, zoning would involve no
planning at all, only the rubber-stamping by the local legislature of the current use of the
land. Moreover, according to the definition of reclassification, the specified non-agricultural
use of the land must be embodied in a land use plan, and the land use plan is enacted
through a zoning ordinance. Thus, zoning and planning ordinances take precedence over
reclassification. The reclassification of land use is dependent on the zoning and land use
plan, not the other way around. It may, therefore, be reasonably presumed that when city
and municipal boards and councils approved an ordinance delineating an area or district in
their cities or municipalities as residential, commercial, or industrial zone, pursuant to the
power granted to them under Section 3 of the Local Autonomy Act of 1959, they were, at
the same time, reclassifying any agricultural lands within the zone for non-agri cultural use;
hence, ensuring the implementation of and compliance with their zoning ordinances. The
logic and practicality behind such a presumption is more evident when considering the
approval by local legislative bodies of subdivision ordinances and regulations. The approval
by city and municipal boards and councils of an application for subdivision through an
ordinance should already be understood to include approval of the reclassification of the
land, covered by said application, from agricultural to the intended non-agricultural use.
Otherwise, the approval of the subdivision application would serve no practical effect; for as
long as the property covered by the application remains classified as agricultural, it could not
be subdivided and developed for non-agricultural use.

In Social Justice Society (Sjs), Vladimir Alarique T. Cabigao and Bonifacio S. Tumbokon
v. Hon. Jose L. Atienza, Jr., G.R. No. 156052, February 13, 2008, we have ruled in previous
cases that when a mandamus proceeding concerns a public right and its object is to compel
a public duty, the people who are interested in the execution of the laws are regarded as the
real parties in interest and they need not show any specific interest. On the other hand, the
Local Government Code imposes upon respondent the duty, as city mayor, to "enforce all
laws and ordinances relative to the governance of the city. One of these is Ordinance No.
8027. As the chief executive of the city, he has the duty to enforce Ordinance No. 8027 as
long as it has not been repealed by the Sanggunian or annulled by the courts. He has no
other choice. It is his ministerial duty to do so.
In The Metropolitan Manila Development Authority and Bayani Fernando as Chairman
v. Viron Transportation Co., Inc., G.R. No. 170656, August 15, 2007, the authority of the
President to order the implementation of the Project notwithstanding, the designation of
the MMDA as the implementing agency for the Project may not be sustained. It is ultra vires,
there being no legal basis therefor. It bears stressing that under the provisions of E.O. No.
125, as amended, it is the DOTC, and not the MMDA, which is authorized to establish and
implement a project such as the one subject of the cases at bar. Thus, the President,
although authorized to establish or cause the implementation of the Project, must exercise
the authority through the instrumentality of the DOTC which, by law, is the
primary implementing and administrative entity in the promotion, development and
regulation of networks of transportation, and the one so authorized to establish and
implement a project such as the Project in question. By designating the MMDA as the
implementing agency of the Project, the President clearly overstepped the limits of the
authority conferred by law, rendering E.O. No. 179 ultra vires.

In Lucena Grand Central Terminal v. JAC Liner, G.R. No. 148339, February 23, 2005, the
court upheld the ruling of the Court of Appeals to declare as null and void Lucena’s City
Ordinance 1778 and Section 4(c) of City Ordinance 1631. City Ordinance 1631 which states
that “an ordinance granting the Lucena Grand Central Terminal Inc., a franchise to construct,
establish, and operate a common bus – jeepney terminal facility in the city of Lucena” was
ruled to be a valid exercise of police power. As the ordinance granted franchise to Lucena
Grand Central Terminal Inc., to construct, finance, establish, operate and maintain common
bus jeepney terminal facility in the city of Lucena. The court though ruled that Section 4(c)
of the City Ordinance which states that “It shall not grant any third party any privilege and/or
concession to operate a bus, mini-bus, and/or jeepney terminal.” The Court of Appeals ruled
that this contravenes Republic Act No. 7160, also known as the Local Government Code. On
the other hand, City Ordinance 1778 was also declared to be null and void as the decision of
the Court of Appeals was maintained that the said ordinance does not meet the 2nd requisite
of a valid police power; which is the lawful method/means. The first requisite was indeed
met, lawful subject as the ordinances has the objective of relieving traffic congestion in the
City of Lucena, involving public interest warranting the interference of the state. However,
the 2nd requisite as before is not met as it should be the reasonableness of the method that
is to be looked up on and not on the effectivity of it to the objective. They also go beyond
what is reasonable to solve the traffic problem. In addition, the bus terminals are not
obstacles on the streets contrary to the argument of the petitioner that this is part of the
power to regulate on streets and bridges, and to prohibit encroachments and obstacles.
Hence the petition of the Lucena Grand Central Terminal is denied and that City Ordinance
1631 is indeed a valid exercise of police power except for its Section 4(c) which is declared as
ultra-vires. City Ordinance 1778 is also declared null and void, for being ultra vires as it arises
from an invalid, oppressive and unreasonable exercise of police power.

In the case of Valentino Legaspi v. City of Cebu, G.R. No. 159110, December 10, 2013,
the court denied the petition and that the decision of the Court of Appeals which reversed
the decision of the Regional Trial Court was maintained. This declared the act in question to
be a valid exercise of police power being exercised by the City of Cebu through the
Sangguniang Panglungsod and granted by Republic Act 7160, also known as the Local
Government Code. Section 458 of the Code states the regulation by the Sangguniang
Panglungsod to its streets, bridges and similar public places as well as the prevention of
encroachments or obstacles thereon. Founded on clear authority and tradition, this
ordinance granting authority to traffic enforcers to immobilize and tow illegally parked
vehicles may be seen as a valid exercise of police power. This was also found to be necessary
because of the traffic congestion caused by illegal parking and also it is designed to improve
traffic conditions in the City, showing a real and substantial relation to the welfare, comfort
and convenience of the people of Cebu. As to the general welfare clause, the measure in
question in the case is within the parameters as this ordinance in the case is reasonable,
consonant with the general powers and purposes of the corporation, consistent with
national laws and policies and also not discriminatory.

II. POWER OF EMINENT DOMAIN

In the case of Manila Memorial Park v. Secretary, DSWD, G.R. No. 175356, December 3,
2013, the petitioners questioned the constitutionality of Section 4 of Republic Act 7432
which granted senior citizens privileges and discounts on different necessities such as
medicines, transportation services, restaurants, as the private establishments may claim the
cost as tax credit. RA 9257 amended RA 7432 to which burial and funeral services was
included for their discounts along with the discounted necessities in the first RA. RA 7432
allows the private establishments to claim tax credit the discounts they give, such it shall be
deducted by the establishment from their income tax provided that they keep records of the
purchases made by senior-citizen customers such as the name and identification number.
They argue that this contradicts article 3 Section 9 of the constitution which states that
“private property shall not be taken for public use without just compensation” and that the
tax deduction scheme does not meet the requirements of just compensation. Based on the
case cited by the petitioners, the discount of 20% given is tantamount to taking of private
property to public use requires the payment of just compensation. They also aver that the
decision in the case of Carlos Superdrug Corporation as the tax deduction scheme is justified
by police power should be reversed. They contend that eminent domain should not be taken
as less supreme to police power. The court although maintained the ruling in the case of
Carlos Superdrug that the validity of the 20% discount and the tax deduction scheme under
RA 9257 is a valid exercise of police power. If in case that the tax deduction is an exercise of
eminent domain, it is indeed unconstitutional as it constitutes taking of private property
without just compensation. But, this was maintained to be a valid exercise of police power
therefore no compensation is warranted. The discounts intends to give and promote
welfare for senior citizens who in their age maybe less likely to be employed, more prone to
illness and such. As this law regulate public utilities to protect consumers as this belongs to
price regulatory measures which affects the profitability of establishments which makes the
subject regulation a police power measure.

In Lagcao v. Judge Labrada, G.R. 155746, October 12, 2004, the court ruled that the
foundation of the right to exercise eminent domain is genuine necessity and that necessity
must be of public character. Government may not capriciously or arbitrarily choose which
private property should be expropriated. In this case, there was no showing at all why
petitioners’ property was singled out for expropriation by the city ordinance or what
necessity impelled the particular choice or selection. Ordinance no. 1843 stated no reason
for the choice of petitioners’ property as the site of a socialized housing project. Moreover,
under RA 7279, private lands rank last in the order of priority for purposes of socialized
housing. In the same vein, expropriation proceedings maybe resorted to only after the other
modes of acquisition are exhausted.

Thus, the ordinance in question is likewise null because: (1) it is repugnant to the
pertinent provisions of RA 7279 and 7160 (LGC); (2) the precipitate manner in which it was
enacted was plain oppression masquerading as pro-poor ordinance; (3) the fact that the
land was singled out manifests partiality against petitioners; (4) it failed to show that there
was reasonable relation between the end sought and the means adopted.

The court reiterated in Republic (DPWH) v. Ortigas and Company Limited Partnership,
G.R. No.171496, March 3, 2014 that the owner of a property taken is entitled to be
compensated when there is taking of private property for some public purpose.
Taking occurs when the following elements are present:

1. The government must enter the private property;

2. The entrance into the private property must be indefinite or permanent;

3. There is color of legal authority in the entry into the property;

4. The property is devoted to public use or purpose;

5. The use of property for public use removed from the owner all beneficial enjoyment of the
property.

All of the above elements are present in this case. Moreover, since the Constitution
proscribes taking of private property without just compensation, any taking must entail a
corresponding appropriation for that purpose. When the road or street was delineated upon
government request and taken for public use, as in this case, the government has no choice
but to compensate the owner for his or her sacrifice, lest it violates the constitutional
provision against taking without just compensation.

In the famous case of Hacienda Luisita Inc. (HLI) v. Presidential Agrarian Reform
Council (PARC), et al., G.R. No. 171101, April 24, 2012, the court held that the for the purpose
of determining just compensation, the date of “taking” is November 21, 1989 (the date when
PARC approved HLI’s SDP) since this is the time that the FWBs were considered to own and
possess the agricultural lands in Hacienda Luisita. To be precise, these lands became subject
of the agrarian reform coverage through the stock distribution scheme only upon the
approval of the SDP, that is, on November 21, 1989. Such approval is akin to a notice of
coverage ordinarily issued under compulsory acquisition. On the contention of the minority
that the date of the notice of coverage [after PARC’s revocation of the SDP], that is, January
2, 2006, is determinative of the just compensation that HLI is entitled to receive, the Court
majority noted that none of the cases cited to justify this position involved the stock
distribution scheme. Thus, said cases do not squarely apply to the instant case. The
foregoing notwithstanding, it bears stressing that the DAR's land valuation is only
preliminary and is not, by any means, final and conclusive upon the landowner. The
landowner can file an original action with the RTC acting as a special agrarian court to
determine just compensation. The court has the right to review with finality the
determination in the exercise of what is admittedly a judicial function.
In Reyes v National Housing Authority, G.R. No. 147511, January 20, 2003 the court
stresses on the term “public use” as synonymous with “public interest”, “public benefit”,
“public welfare”, and “public convenience”. Also, the Court states that the 1987
Constitution explicitly provides for the valid exercise of the power of eminent domain over
the private properties upon payment of just compensation. Further, Section 9, Article III
states that private property shall not be taken for public use without just compensation. The
constitutional restraints are public use and just compensation, hence, the act of NHA in
entering a contract with a real estate developer for the construction of low cost housing
cannot be taken to mean as a deviation from the stated public purpose of their taking.

The expropriation judgment declared that NHA has a lawful right to take petitioners
properties “for the public use or purpose of expanding the Dasmarinas Resettlement
Project”. Expropriation of private lands for slum clearance and urban development is for a
public purpose even if the developed area is later sold to private homeowners, commercial
firms, entertainment and service companies and other private concerns.

The Court ruled, in the case of Republic v. Soriano, G.R No. 211666, February 25, 2015, that
payment of just compensation for the expropriated property amounts to an effective
forbearance on the part of the State. The law applicable is the Central Bank Circular and not
the Civil Code. RTC’s reliance on National Power Corporation v. Angas is misplaced for the
same has already been overturned by Republic v Court of Appeals, where the court held that
the payment of just compensation for the expropriated property amounts to an effective
forbearance on the part of the State. In line with the recent circular of the Monetary Board
of the Bangko Sentral ng Pilipinas (BSP-MB) No. 799, Series of 2013, the prevailing rate of
interest for loans or forbearance of money is six percent (6%) per annum.

Further, the imposition of interest is unnecessary because petitioner was able to


deposit with the trial court the amount representing the zonal value of the property before
its taking. The award of interest is imposed in the nature of damages for delay in payment to
ensure prompt payment of the value of the land and limit the opportunity loss of the owner.
However, when there is no delay in the payment of just compensation, there should be no
imposition of interest.

In the case of National Power Corporation v. Tarcelo and Santos, G.R No. 198139
September 8, 2008 the petitioner is adjudged liable to pay just compensation to Felicisimo
Tarcelo and the Heirs of Comia Santos for the affected portions of their respective
properties totaling 1,595.91 square meters, at P797.50 per square meter.

It is not declared that NPC should pay for the entire area of respondent’s properties,
but rather, pay the full and fair market value of the property and not merely pay a 10%
easement fee. Stated simply, the NPC should pay for the full per-square meter value of the
affected portions, and not just the fraction thereof. The reason why the respondents are
entitled to the full market value of the affected portions of their lands is that the
construction of underground pipeline is a simple case of mere passage of gas pipeline. It will
surely cause damage and prejudice to the agricultural potentials of appellees’ property.
Deep excavation will have to be done whereby plants and trees will be uprooted. A possible
leakage could certainly do harm and adversely restrict the agricultural and economic activity
of the land. This is not to mention that it will create an environmental health hazard
dangerous to the occupant’s life and limb.

The Court notes that the exercise of the right of eminent domain, whether directly by
the State or by its authorized agents, is necessarily in derogation of private rights. When the
power is granted, the extent to which it may be exercised is limited to the express terms or
clear implication of the statute in which the grant is contained. Upon payment of just
compensation to the defendants, subject to the deductions of the sums due the
Government for unpaid real estate taxes and other imposts, the plaintiff shall have a lawful
right to enter, take possession and acquire easement of right-of-way over the portions of
the properties together with the improvements sought to be expropriated for the purpose
stated, free from any and all liens and encumbrances.

In the case of Landbank v. Gallego, G.R. No. 173226, July 29, 2013, where there is a
dispute as to the amount of just compensation, the method to be used in the determination
of the value of the land must result to a fair and reasonable amount and must not drastically
reduce the said value. Just compensation refers to full and fair equivalent of the property
taken from the owner and to be "just," the compensation must be real, substantial, full and
ample.

In NPC v. Spouses Samar, G.R. No. 197329, September 8, 2014, just compensation for
the property must be based on its value at the time of the taking of said property, not at the
time of the filing of the complaint. Consequently, the RTC should have fixed the value of the
property at the time NPC took possession of the same in 1990, and not at the time of the
filing of the complaint compensation and damages in 1994 or its fair market value in 1995.

In Republic v. Lim, G.R. No. 161656, June 29, 2005, in summation, while the prevailing
doctrine is that "the non-payment of just compensation does not entitle the private
landowner to recover possession of the expropriated lots, however, in cases where the
government failed to pay just compensation within five (5) years from the finality of the
judgment in the expropriation proceedings, the owners concerned shall have the right to
recover possession of their property. This is in consonance with the principle that "the
government cannot keep the property and dishonor the judgment." To be sure, the five-year
period limitation will encourage the government to pay just compensation punctually. This is
in keeping with justice and equity. After all, it is the duty of the government, whenever it
takes property from private persons against their will, to facilitate the payment of just
compensation. In Cosculluela v. Court of Appeals, we defined just compensation as not only
the correct determination of the amount to be paid to the property owner but also the
payment of the property within a reasonable time. Without prompt payment, compensation
cannot be considered "just."

In Heirs of Dr. Jose Deleste vs. Land Bank, G.R. No. 169913, June 8, 2011, the Court held
that the subject property involved is outside the coverage of the agrarian reform program in
view of the enactment by the City of Iligan of its local zoning ordinance, City Ordinance No.
1313. City Ordinance No. 1313 was enacted by the City of Iligan in 1975. Significantly, there
was still no HLURB to speak of during that time. It was the Task Force on Human
Settlements, the earliest predecessor of HLURB, which was already in existence at that time,
having been created on September 19, 1973 pursuant to Executive Order No. 419. It should
be noted, however, that the Task Force was not empowered to review and approve zoning
ordinances and regulations. As a matter of fact, it was only on August 9, 1978, with the
issuance of Letter of Instructions No. 729, that local governments were required to submit
their existing land use plans, zoning ordinances, enforcement systems and procedures to
the Ministry of Human Settlements for review and ratification. The Human Settlements
Regulatory Commission (HSRC) was the regulatory arm of the Ministry of Human
Settlements. This leads to the conclusion that City Ordinance No. 1313 enacted by the City
of Iligan was approved by the HSRC, the predecessor of HLURB. The validity of said local
zoning ordinance is, therefore, beyond question. Since the subject property had been
reclassified as residential/commercial land with the enactment of City Ordinance No. 1313 in
1975, it can no longer be considered as an agricultural land within the ambit of RA 6657.

III. POWER OF TAXATION

In the case of MIAA vs. CA, G.R. No. 155650, July 20, 2006, the Supreme Court held
that Airport Lands and Buildings of MIAA are exempt from real estate tax because of two
reasons: first, MIAA is not a government-owned or controlled corporation but
an instrumentality of the National Government and thus exempt from local taxation and
second, the real properties of MIAA are owned by the Republic of the Philippines and thus
exempt from real estate tax. MIAA is a government instrumentality vested with corporate
powers to perform efficiently its governmental functions. It falls under Section 133(o) of the
Local Government Code where it recognizes the basic principle that local governments
cannot tax the national government. The only exception is when MIAA leases its real
property to a taxable person as provided in Section 234(a) of the Local Government Code, in
which case the specific real property leased becomes subject to real estate tax. Thus, only
portions of the Airport Lands and Buildings leased to taxable persons like private parties are
subject to real estate tax by the City of Paranaque. Under Article 420 of the Civil Code,
the Airport Lands and Buildings of MIAA, being devoted to public use, are properties
of public dominion and thus owned by the State or the Republic of the Philippines. Article
420 specifically mentions ports constructed by the State, which includes public airports and
seaports, as properties of public dominion and owned by the Republic. As properties of
public dominion owned by the Republic, there is no doubt that the Airport Lands and
Buildings are expressly exempt from real estate tax under Section 234(a) of the Local
Government Code.

In Physical Therapy Organization v. Municipal Board of Manila, G.R. No. L-10448,


August 30, 1957, as regards the permit fee of P100.00 payable by the operator of the
massage clinic, the Court held that the Manila Municipal Board imposed the said permit fee
for its regulation. The amount of the fee or charge is properly considered in determining
whether it is a tax or an exercise of the police power. The amount may be so large as to itself
show that the purpose was to raise revenue and not to regulate, but in regard to this matter
there is a marked distinction between license fees imposed upon useful and beneficial
occupations which the sovereign wishes to regulate but not restrict, and those which
are inimical and dangerous to public health, morals or safety. The Manila Municipal Board
considered the practice of hygienic and aesthetic massage not as a useful and beneficial
occupation which will promote and is conducive to public morals. Compared to permit fees
required in other operations, P100.00 may appear to be large and unreasonable but it is
imposed in order to discourage non-useful occupations or enterprises. The fee may be large
without necessarily being a tax.

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