CONSTITUTIONAL LAW CASES
1. SPARK V. QC (G.R. NO. 225442. AUGUST 08, 2017)
WHEN LEGAL STANDING MAY BE RELEAXED
Indeed, when those who challenge the official act are able to craft an issue of
transcendental significance to the people, the Court may exercise its sound discretion and
take cognizance of the suit. It may do so in spite of the inability of the petitioners to show
that they have been personally injured by the operation of a law or any other government
act."[46]
VOID FOR VAGUENESS AS A SPECIE OF UNCONSTITUTIONAL UNCERTAINTY (A DUE
PROCESS CONCEPT)
A statute or act suffers from the defect of vagueness when it lacks comprehensible
standards that men of common intelligence must necessarily guess at its meaning and
differ as to its application. It is repugnant to the Constitution in two (2) respects: (1) it
violates due process for failure to accord persons, especially the parties targeted by it, fair
notice of the conduct to avoid; and (2) it leaves law enforcers unbridled discretion in
carrying out its provisions and becomes an arbitrary flexing of the Government muscle."
[T]he vagueness doctrine is a specie of "unconstitutional uncertainty," which may involve
"procedural due process uncertainty cases" and "substantive due process uncertainty
cases." "Procedural due process uncertainty" involves cases where the statutory language
was so obscure that it failed to give adequate warning to those subject to its prohibitions
as well as to provide proper standards for adjudication. Such a definition encompasses
the vagueness doctrine. This perspective rightly integrates the vagueness doctrine with
the due process clause, a necessary interrelation since there is no constitutional provision
that explicitly bars statutes that are "void-for-vagueness."
CURFEW ORDINACE DOES NOT VIOLATE OR ENCROACH PARENTAL RIGHT TO REAR
CHILDREN
While parents have the primary role in child-rearing, it should be stressed that "when
actions concerning the child have a relation to the public welfare or the well-being of the
child, the [S]tate may act to promote these legitimate interests."[66] Thus, "[i]n cases in
which harm to the physical or mental health of the child or to public safety, peace, order,
or welfare is demonstrated, these legitimate state interests may override the parents'
qualified right to control the upbringing of their children."
[W]here minors are involved, the State acts as parens patriae. To it is cast the duty of protecting
the rights of persons or individual who because of age or incapacity are in an unfavorable position,
vis-a­ vis other parties. Unable as they are to take due care of what concerns them, they have the
political community to look after their welfare. This obligation the state must live up to. It cannot
be recreant to such a trust. As was set forth in an opinion of the United States Supreme Court:
"This prerogative of parens patriae is inherent in the supreme power of every State, x x x."[69]