Araneta v Dinglasan Digest

Araneta v Dinglasan

G.R. No. L-2044  August 26, 1949

Tuason, J.:

Facts:

1.    The petitions challenged the validity of executive orders issued by virtue of CA No. 671 or the Emergency Powers Act. CA 671 declared a state of emergency as a result of war and authorized the President to promulgate rules and regulations to meet such emergency. However, the Act did not fix the duration of its effectivity.  

2.       EO 62 regulates rentals for houses and lots for residential buildings. The petitioner, Araneta, is under prosecution in the CFI for violation of the provisions of this EO 62 and prays for the issuance of the writ of prohibition.

3.       EO 192, aims to control exports from the Philippines. 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. Both officials refuse to issue the required export license on the ground that the exportation of shoes from the Philippines is forbidden by this EO.

4.       EO 225, which appropriates funds for the operation of the Government during the period from July 1, 1949 to June 30, 1950, and for other purposes was assailed by petitioner Eulogio Rodriguez, Sr., as a tax-payer, elector, and president of the Nacionalista Party. He applied for a writ of prohibition to restrain the Treasurer of the Philippines from disbursing the funds by virtue of this EO.

5.    Finally, EO 226, which appropriated P6M to defray the expenses in connection with the national elections  in 1949. was questioned by Antonio Barredo, as a citizen, tax-payer and voter. He asked the Court to prevent "the respondents from disbursing, spending or otherwise disposing of that amount or any part of it."

ISSUE: Whether or not CA 671  ceased to have any force and effect

YES. 

1. The Act fixed a definite limited period. The Court held that it became inoperative when Congress met during the opening of the regular session on May 1946 and that EOs 62, 192, 225 and 226 were issued without authority of law . The session of the Congress is the point of expiration of the Act and not the first special session after it.
2.  Executive Orders No. 62 (dated June 21, 1947) regulating house and lot rentals, No. 192 (dated December 24, 1948) regulating exports, Nos. 225 and 226 (dated June 15,1949) the first appropriation funds for the operation of the Government from July 1, 1949 to June 30, 1950, and the second appropriating funds for election expenses in November 1949, were therefore declared null and void for having been issued after Act No. 671 had lapsed and/or after the Congress had enacted legislation on the same subjects. This is based on the language of Act 671 that the National Assembly restricted the life of the emergency powers of the President to the time the Legislature was prevented from holding sessions due to enemy action or other causes brought on by the war.