The issue of imposing a curfew for minors has long been a subject of debate. Proponents of curfews argue that they are essential to protect minors from crimes and to promote their safety.

Some, however, contend that the imposition of a curfew infringes on the right of children to freely travel within their respective localities, as well as their parents' natural and primary right to rear their children.

Preliminarily, as parens patriae, the State has the inherent right and duty to aid parents in the moral development of their children (Spouses Imbong v. Ochoa Jr., G.R. No. 204819, 8 April 2014). Article 139 of Presidential Decree No. 603, also known as the Child and Youth Welfare Code, authorizes Local Government Units to set curfew hours for children. The Code states, "City or municipal councils may prescribe such curfew hours for children as may be warranted by local conditions."

However, while rights may be restricted, such restriction must be narrowly drawn only to the extent necessary to achieve the purpose of the governmental regulation.

In the case of Samahan ng mga Progresibong Kabataan (SPARK) v. Quezon City, City of Manila, and Navotas City (G.R. No. 225442, 8 August 2017), the Supreme Court examined and ruled upon the constitutionality of the different curfew ordinances imposed by the three LGUs.

Ultimately, the Supreme Court upheld the validity of the Quezon City ordinance, while the Manila and Navotas ordinances were declared unconstitutional for overly restricting minors' fundamental freedoms.