In the leading case of Churchill vs. Rafferty, Act No. 2339 authorized the Collector of Internal Revenue to remove after due investigation, any billboard showing to public view that it is offensive to the sight or is otherwise a nuisance. Things offensive to the senses, such as sight, smell or hearing, may be blocked by the State especially those situated in thickly populated districts. What the case imparts is that aesthetics may be regulated by the police power of the state, as long as it is justified by public interest and safety. (Marquez & Garcia,
