Title: Araneta vs. Dinglasan DoP: 26 August 1949 Ponente: Tuason Nature: Original Action in the SC.

Prohibition and Mandamus. Facts: y Involves 5 cases where petitioners challenged the validity of EOs issued by the President by virtue of Act. No 671: o L-2044 and L-2756; Araneta vs Dinglasan and Araneta vs. Angeles; assails EO 62 which regulates rentals for houses and lots for residential buildings o L-3055; Leon Ma. Guerrero vs The Commisioner of Customs; assails EO 192 which aims to control exports from the Philippines o L-3054; Rodriguez vs Treasurer of the Philippines; assails EO 225 which appropriates funds for he operation of the RP during July 1, 1949 to June 30, 1950 o L-3056; Barredo vs COMELEC; assails EO 226 which appropriates 6 m to defray expenses in connection to the coming national elections All rest their case on the unconstitutionality of the Emergency Powers Act (Commonwealth Act. No. 671) For purpose of the decision, Act No. 61s constitutionality will be taken for granted. y Act. No. 671 AN ACT DECLARING A STATE OF TOTAL EMERGENCY AS A RESULT OF WAR INVOLVING THE PHILIPPINES AND AUTHORIZING THE PRESIDENT TO PROMULGATE RULES AND REGULATIONS TO MEET SUCH EMERGENCY o Sec 1: War makes it necessary to invest Pres. with extraordinary powers in order to meet resulting emergency o Sec 2: Pursuant to Article 6, sec. 26 of the Consti, the President is hereby authorized to promulgate such rules and regulations he may deem necessary to carry out the national policy declared in sec 1. Pres is allowed to: a. transfer seat of government b. reorganize government c. create new subdivisions of government d. continue in force laws and appropriations that would otherwise lapse/be inoperative e. impose/increase/reduce/abolish new taxes f. raise funds through issuance of bonds g. authorize national/city/municipal governments to incur overdrafts as per his approval h. declare suspension of collection of credits/payment of debts i. exercise any power he deems necessary to enable government to fulfill its responsibilities o Sec 3: President will report on his issuances when Congress convenes o Sec 4: Shall be in force unless otherwise provided Does not fix term/duration of its effectiveness y Art 6, Sec 26 of the 1935 Constitution: In time of war or other national emergency, the Congress may by law authorize the President, for a limited period and subject to such restrictions as it may prescribe, to promulgate rules and regulations to carry out a declared national policy limited: restricted, bounded, prescribed, confined within positive bounds, restrictive in duration/extent/scope. Issue: WoN the assailed EOs are invalid as it was issued using Act. 671 A. WoN Act 671 is only valid for a limited time B. When did Act.671 become ineffective? Ruling: Petitions granted. (EOs are invalid as they were issued after Act. 671 had already become ineffective) Reasoning: A. Act 671 is only valid for a limited time. y Emergency Powers only becomes justified delegation of powers only if it is temporary Temporary or else its not an emergency. Thus, it is presumed Act 671 was approved with a limitation in mind. y The assertion that a new law is needed to repeal Act 671 does not make sense either as the repeal may not be approved by the President and the Congress may not override the veto. Also, this would create the anomaly that would make it easier for Congress to delegate their powers than to take it back as delegation of power occurred by simple majority and a recall would need 2/3 votes.

Sec 4 is silent regarding the repeal of authority in the face of express provision for the repeal of the rules and regulations issued in pursuance of it is a clear manifestation that the NA believed there was no necessity to provide for the former. If Executive continues to exercise legislative powers, Congress and the President could (as Aranetas case) mutually nullify each others actions. Language of Act 671 itself restricts the life of the emergency powers of the President to the time Legislature was prevented from holding sessions due to enemy action or other causes brought on by the way Sec 3: Requirement that President report on his issuance once Congress has convened. Intent behind Act 671 also evident in Quezons autobiography He was the one who called NA to a special session to enact Act 671 He stated that it was only for a limited period, and a new law is needed to keep it alive.

B. Act 671 became inoperative when Congress met in regular session on May 25, 1946 (assailed EOs were issued without authority of the law). y Quezons biography call for special session to enact Act 671 came about when it became evident that the country was completely helpless against air attacks and it was most unlikely the Phil. Legislatire would hold its next regular session. Thus NA delegated its powers/abdicated its powers to the President only when it was clear the NA would be unable to meet. The enactment of Act 671, which is destructive of the foundation of democratic institutions, could only have been made in circumstances where there is a complete disruption and dislocation of the normal processes of government. Notes: y Court did not decide on which department is authorized to inquire whether the contingency on which the law is predicated still exists. In this case, the Court merely applied the law. On the contention that Pres has the exclusive authority to say the war has not ended, not legal principle can be found to support this. PRESIDENTS AUTHORITY (IN THIS CASE) IS PURELY STATUTORY, NOT DERIVED FROM CONSTI y Even in times of extreme peril, the legislation is preserved for Congress. Actually, it is in times of peril that the various branches of government are (more than normal) called to act. Votes: 4 concur with ponente