

Beltran v. Secretary of Health

L-81958 , June 30 , 1988 , 163 SCRA 386 . 51 .

A petition challenging the constitutionality of Section 7 of

Republic Act No. 7719, which mandates the phase-out of
commercial blood banks, is brought to the Supreme Court,
who ultimately rules in favor of the law, stating that it is a
valid exercise of the state's police power to safeguard
public health and promote a safe and adequate supply of
blood through voluntary donation.

G.R. No. 71169, 74376, 76394, 78182, 82281,

60727 • SARMIENTO, J

1989-08-25

Sangalang v. Intermediate Appellate Court

No . 81958 , June 30 , 1988 . 16 .

The case involves a dispute over the opening of Jupiter

and Orbit Streets in Bel-Air Village, with the court
ultimately ruling that the Mayor of Makati had the legal
authority to open the streets for public use in order to
alleviate traffic congestion and promote the general
welfare.

Showing 1 to 10 of 10 results

JurisprudenceAI SummaryAI Digest

Title

Philippine Association of Service Exporters, Inc. v. Drilon

Case

G.R. No. 81958

Ponente

SARMIENTO, J :

Decision Date

1988-06-30

Facts
This case involves a challenge to the Constitutional validity of
Department Order No. 1, Series of 1988, which temporarily
suspends the deployment of Filipino domestic and household
workers. The petitioner, Philippine Association of Service
Exporters, Inc. (PASEI), argues that the measure is
discriminatory, as it only applies to domestic helpers and
females with similar skills. PASEI also claims that the order
violates the right to travel and is an invalid exercise of the
lawmaking power. PASEI further argues that the order was
passed without prior consultations and violates the non-
impairment clause of the Constitution.

The respondents, the Secretary of Labor and Employment and

the Administrator of the Philippine Overseas Employment
Administration, argue that the order is a valid exercise of the
state's police power. They contend that the order is necessary
to protect Filipino female overseas workers who have been
subjected to exploitation and abuse. They also argue that the
order does not violate the equal protection clause of the
Constitution, as it is based on substantial distinctions and
applies equally to all members of the same class.
Issue
The main issues raised in this case are:

1. Whether Department Order No. 1, Series of 1988 is

discriminatory and violates the right to travel.
2. Whether the order is an invalid exercise of the lawmaking
power.
3. Whether the order was passed without prior consultations
and violates the non-impairment clause of the
Constitution.

Ruling
The court dismisses the petition, stating that the order is a
valid exercise of the state's police power.

Ratio
The court explains that police power is the state's authority to
enact legislation that may interfere with personal liberty or
property in order to promote the general welfare. It is a
fundamental attribute of government and is not specifically
granted by the Constitution. However, police power is not
without limitations and must be exercised reasonably and for
the public good.

The court finds that the order does not make an undue
discrimination between the sexes. It is based on substantial
distinctions, as there is evidence of the mistreatment and
exploitation of female domestic workers abroad. The court
notes that there is no evidence of similar mistreatment of male
workers. Therefore, the classification is justified.

The court also finds that the order is applicable to all female
domestic overseas workers and does not violate the equal
protection clause. The court explains that the Constitution
prohibits singling out a select person or group of persons
within an existing class to the prejudice of such a person or
group. The order accords protection to certain women workers
and does not give unfair advantage to another person or group.

Summary
In summary, this case involves a challenge to the
Constitutional validity of Department Order No. 1, Series of
1988, which temporarily suspends the deployment of Filipino
domestic and household workers. The petitioner argues that
the measure is discriminatory and violates various
constitutional provisions. However, the court dismisses the
petition and upholds the validity of the order, stating that it is
a valid exercise of the state's police power. The court finds
that the order is based on substantial distinctions and does
not violate the equal protection clause. The order aims to
protect female domestic workers from exploitation and abuse
and does not give unfair advantage to another person or group.
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