Antonio Araneta vs Rafael Dinglasan

Consolidated Cases
August 26, 1949

Briefed by Val Charles C. Ringor

TUASON, J.:

Five cases where consolidated in this instant case all questioning the validity of
executive issuances by virtue of Commonwealth Act 671 also known as Emergency
Powers Act, a law granting emergency powers to the president of the Philippines. It
is argued that the said act has ceased to have any force and effect.

 In the first two cases GR-2044 and 2756, the petitioner, Araneta,
questions EO 62 which regulates rentals for houses and lots for
residential buildings. The petitioner, J. Antonio Araneta, is under
prosecution in the Court of First Instance of Manila for violation of the
provisions of this EO 62, and prays for the issuance of the writ of prohibition
to the judge and the city fiscal.

 For the third case GR L-3054, it relates to Executive Order No. 225,
which appropriates funds for the operation of the Government of the
Republic of the Philippines during the period from July 1, 1949 to June
30, 1950, and for other purposes. The petitioner Eulogio Rodriguez, Sr., as a
tax-payer, wishes to restrain the Treasurer of the Philippines from disbursing
this Executive Order.

 For the fourth case L-3055 is Executive Order No. 192, which aims to
control exports from the Philippines. In this case, Leon Ma. Guerrero seeks
a writ of mandamus to compel the Administrator of the Sugar Quota Office
and the Commissioner of Customs to permit the exportation of shoes by the
petitioner.

 For the last case, is Executive Order No. 226, which appropriates
P6,000,000 to defray the expenses in connection with, and incidental to, the
hold lug of the national elections to be held in November, 1949. The petitioner,
Antonio Barredo, as a citizen, tax-payer and voter, asks this Court to prevent
"the respondents from disbursing, spending or otherwise disposing of that
amount or any part of it.

ISSUE: Whether the Act, without fixing the duration of its effectivenss, ceased to
have force and effect. (Yes, Petitions are granted the assailed EOs are null and void for being
issued after Act 671 has lapsed)
HELD:

Discussions

complete disruption and dislocation of the normal processes of government

If we are to argue the Act is still in effect when the Congress met in regular session, the
President will have the power to restore any executive issuance rendered inoperative by
Congress thus an anomally.

It is annomalous to have the executive to exercise legislative function when the Congress is in
the unobstructed exercise of its functions as there will be two legislative bodies operating
over the same field. Even if the said powers be suspended during regular session of Congress,
the anomally will still remain.
 With respect to power of the president in the instant case, “The President's authority in this
connection is purely statutory, in no sense political or directly derived from the Constitution.”

The truth is that under our concept of constitutional government, in times of extreme perils
more than in normal circumstances "the various branches, executive, legislative, and judicial,"
given the ability to act, are called upon "to the duties and discharge the responsibilities
committed to them respectively." verbatim

The Court’s Ruling

Article VI of the Constitution provides that any law passed by virtue thereof
should be "for a limited period." "Limited" has been defined to mean
"restricted; bounded; prescribed; confined within positive bounds; restrictive
in duration, extent or scope. It is to be presumed that Commonwealth Act No.
671 was approved with this limitation in view. verbatim

Section 3 of Commonwealth Act No.671 provides:

“The President of the Philippines shall as soon as practicable upon the

convening of the Congress of the Philippines report thereto all the
rules and regulations promulgated by him under the powers herein
granted.” The clear tenor of this provision is that there was to be only
one meeting of Congress at which the President was to give an account
of his trusteeship.

The silence of the law(Act No. 671) regarding repeal of authority itself is a
clear manifestation that there is no need for an express provision to repeal
the rules and regulations made pursuant to it.

Mr. Quezon, who called the National Assembly to a special session, who
recommended the enactment of the Emergency Powers Act, that Act No. 671
was only "for a certain period" and "would become invalid unless reenacted."
These phrases connote automatical extinction of the law upon the conclusion
of a certain period. A new legislation was necessary to keep alive (not to
repeal).“It is our considered opinion, and we so hold, that Commonwealth
Act No. 671 became inoperative when Congress met in regular session on
May 25, 1946, and that Executive Orders Nos. 62, 192, 225 and 226 were
issued without authority of law.” verbatim

“Act No. 671, as we have stressed, ended ex proprio vigore with the opening of
the regular session of Congress on May 25, 1946.” verbatim