SPARK v.

Quezon City

President Rodrigo Roa Duterte sought to implement a nationwide curfew for minors,
several cities in Metro Manila started to strictly implement their curfew ordinances on
minors through police operations which are calle “Oplan Rody”

Among the cities who implemented curfew ordinances are Novats, Manila, and Quezon
City.

Petitioners filed a case in the Supreme Court assailing the constitutionality of the
ordinances. In one of their arguments, they stated that the ordinance is in violation of the
parent’s natural and primary right in the rearing of the youth.

Issue:

WON the ordinances violates the right of parents to rear their children. NO

Ratio

The Supreme Court stated that according to Sec 12 Article II of the Constitution, the
natural and primary right and duty of the parents in the rearing of the youth for civic
efficiency and the development of moral character shall receive the support of the
Government. The Court recognizes the right and duty of the parent in child-rearing, it
should be noted that when actions concerning the child have a relation to the public
welfare or the well-being of the child, the State may act to promote this legitimate
interest. The State has the inherent right and duty to aid parents in the moral development
of their children.

In this case, the ordinances issued are in line with the interest of the state to aid the
parents in ensuring the welfare of their child. Furthermore, the ordinances only apply
to minors that are not accompanied by their parents. This serves as an explicit recognition
of the State’s regard to the parental authority.