Law School Noob: [CASE DIGEST] Araneta v. Dinglasan (G.R. No. L-2044)

Friday, September 7, 2018

[CASE DIGEST] Araneta v. Dinglasan (G.R. No. L-2044)

August 26, 1949 | 84 Phil. 368

Consolidated petitions

FACTS:

This case is a consolidation of multiple petitions challenging the validity of various executive orders issued pursuant to the President's emergency powers as outlined in Commonweath Act No. 671. The said CA was enacted during a special session by the National Assembly when it became apparent that it was most unlikely the Philippine Legislature would hold its next regular session on January 1, 1942 due to air attacks during WWII. Although the President's emergency powers were supposed to be for a limited period only, CA 671 did not indicate a specific date when such powers would end.

The assailed executive orders included the following:

EO 62, which regulated rentals for houses and lots for residential buildings;
EO 192, which aimed to control exports in the Philippines;
EO 225, which appropriated funds for the operation of the GRP from July 1949 to July 1950; and
EO 226, which appropriated P6M to defray the expenses in connection with the November 1949 elections.

Petitioners argued that the abovementioned EOs enacted pursuant to CA 671 were invalid because the latter had ceased to have any force and effect.

ISSUE:

Whether or not CA 671, otherwise known as the Emergency Powers Act, has ceased to have any force and effect upon the resumption/opening of the regular session of Congress on May 25, 1946.

HELD:

Yes, the Court held that CA 671 ended ex propio vigore with the opening of the regular session of Congress on May 25, 1946.

Section 26, Article VI of the 1935 Constitution states that "in times of war or national emergency, the Congress may by law authorize the President, for a limited period x x x to promulgate rules and regulations to carry out a declared national policy." It is to be presumed CA 671 was promulgated with this limitation in view. In fact, Section 4 of CA 671 stipulates that "the rules and regulations promulgated thereunder shall be in full force and effect until the Congress of the Philippines shall otherwise provide."

There being no definitive expiration period, the Court held that the session of the Congress is the point of expiration of the Act. And since all the assailed EOs were enacted after May 25, 1946, the Court held they are void.

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