People v. Paterno

Summary

This case involved a constitutional challenge to the enforcement procedures of Manila's anti-littering ordinance. Paterno was arrested and detained for throwing a cigarette butt, then convicted and fined. On appeal to the Supreme Court, he challenged not the ordinance itself but the arrest procedures, arguing they were oppressive. The Supreme Court affirmed his conviction, holding that the validity of enforcement procedures is separate from the ordinance's validity. The Court distinguished between challenges to an ordinance's operation versus challenges to enforcement procedures, emphasizing that procedural matters in law enforcement cannot invalidate an otherwise valid ordinance. This decision clarified the separation between municipal legislation and its enforcement mechanisms in constitutional analysis.