ZACARIAS VILLAVICENCIO vs JUSTO LUKBAN

GR No. 14639, March 25, 1919

FACTS:

The Mayor of Manila, Justo Lukban (Lukban), with good intentions, ordered the
segregated district for women of ill repute, which had been permitted for a number of
years in Manila, closed. The women were kept confined to their houses in the district by
the police. The city authorities quietly planned with the Bureau of Labor to send the
women to Davao, Mindanao, as laborers. They had no knowledge that they were ordered
to live in Mindanao. They had not been asked if they wished to leave Manila and had not
given their consent to the deportation.

The petitioner, Victoria Villavicencio, sought legal recourse against the actions of
respondent Mayor Emiliano Lukban of Manila who ordered the forced deportation of
women suspected of prostitution. These women were subjected to inhumane treatment,
including being forcibly taken from their homes, detained, and eventually transported to
Davao, without due process.

ISSUE:

Whether Mayor Lukban's actions, which involved the forced deportation of women,
violated their constitutional rights, including their right to due process and equal
protection under the law.

RULING:

The Supreme Court, in a landmark decision, held that Mayor Lukban's actions were
unconstitutional and violated the fundamental rights of the affected women.

The most critical constitutional right invoked in this case was the right to due process.
Due process is enshrined in the Philippine Constitution, specifically in Article III, Section
1, which states that "No person shall be deprived of life, liberty, or property without due
process of law." The Court held that the forced deportation of the women without proper
legal procedures violated their right to due process. Due process requires that individuals
be given notice and an opportunity to be heard before any deprivation of their rights or
liberty.

Another constitutional basis for the ruling was the right to equal protection of the law,
which is also found in Article III, Section 1 of the Philippine Constitution. This right
ensures that all individuals are treated equally under the law and that they are not
subjected to arbitrary or discriminatory actions by the government. Mayor Lukban's
selective deportation of women based on suspicion of prostitution was seen as a violation
of their equal protection rights, as it targeted a specific group of individuals without a
valid reason.

Furthermore, the Court ruled that the government has a duty to protect the rights and
dignity of all individuals, even those engaged in activities deemed illegal or immoral.

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Mayor Lukban's actions, in this case, were excessive and went against the principles of
justice and fairness.

The case is more about the limits of governmental authority and the protection of
individual rights. It serves as an example of how the legal system should safeguard
individual liberties even in the context of government actions aimed at maintaining order
and security.

In conclusion, the Court ordered the immediate release of the affected women and their
safe return to Manila. This case served as a significant precedent in upholding the
constitutional rights of all individuals, regardless of their circumstances or social status,
and ensuring that the government acts within the bounds of the law.

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