COMPLETE TITLE: Samahan Ng Mga Progresibong Kabataan (Spark) v. Quezon City [ G.R.

No. 225442. August 08, 2017]

RATIO/DOCTRINE: Relevant Jurisprudence on Children
CASE FACTS:
Following the campaign of President Rodrigo Roa Duterte to implement a nationwide
curfew for minors, several local governments in Metro Manila started to strictly implement their
curfew ordinances on minors through police operations which were publicly known as part of
"Oplan Rody."
Among those local governments that implemented curfew ordinances were respondents:
(1) Navotas City, (2) City of Manila, (3) Quezon City.
Petitioners, spearheaded by SPARK - an association of young adults and minors that aims to
forward a free and just society, in particular the protection of the rights and welfare of the youth
and minors10filed this present petition, arguing that the Curfew Ordinances are unconstitutional
because:
 suffer from overbreadth by impairing legitimate activities of minors during curfew hours;
 are unconstitutional as it deprive minors of the right to liberty and the right to travel 
ISSUE/S:
1. WON the Curfew Ordinances are unconstitutional.
2. WON the minors were deprived of the right to liberty and the right to travel without
substantive due process
RULING :
1. Yes, the court partly granted the petition.
  The two ordinances are not narrowly drawn in that their exceptions are inadequate and
therefore, run the risk of overly restricting the minors' fundamental freedoms. The two
ordinances do not account for the reasonable exercise of the minors' rights of association, free
exercise of religion, rights to peaceably assemble, and of free expression, among others. The
Quezon City Ordinance stands in stark contrast to the first two (2) ordinances as it sufficiently
safeguards the minors' constitutional rights.
Thus, two ordinances are declared unconstitutional and the Quezon City Ordinance remains
to be constitutional.
2. Jurisprudence provides that the right to travel is not absolute. As the 1987 Constitution
itself, the State may impose limitations on the exercise of this right, provided that they:
(1) serve the interest of national security, public safety, or public health; and (2) are
provided by law.
The stated purposes of the Curfew Ordinances, specifically the promotion of juvenile safety
and prevention of juvenile crime, inarguably serve the interest of public safety. The restriction on
the minor's movement and activities within the confines of their residences and their immediate
vicinity during the curfew period is perceived to reduce the probability of the minor becoming
victims of or getting involved in crimes and criminal activities.
The restrictions set by the Curfew Ordinances that apply solely to minors are likewise
constitutionally permissible. In this relation, this Court recognizes that minors do possess and
enjoy constitutional rights,108but the exercise of these rights is not co-extensive as those of
adults. For these reasons, the State is justified in setting restrictions on the minors' exercise of
their travel rights, provided, they are singled out on reasonable grounds.