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Home Constitutional Law Ramon Gonzales vs Runo Hechanova
Ramon Gonzales vs Runo Hechanova
9 SCRA 230 Political Law Constitutional Law Treaty vs Executive Agreements Statutes Can Repeal
Executive Agreements
During the term of President Diosdado Macapagal, he entered into two executive agreements with Vietnam
and Burma for the importation of rice without complying with the requisite of securing a certication from
the National Economic Council showing that there is a shortage in cereals or rice. Hence, the then
Executive Secretary, Runo Hechanova, authorized the importation of 67,000 tons of rice from abroad to
the detriment of our local planters. Ramon Gonzales, then president of the Iloilo Palay and Corn Planters
Association assailed the executive agreements. Gonzales averred that Hechanova is without jurisdiction or
in excess of jurisdiction, because Republic Act 3452 prohibits the importation of rice and corn by the
Rice and Corn Administration or any other government agency.
ISSUE: Whether or not RA 3452 prevails over the 2 executive agreements entered into by Macapagal.
HELD: Yes. Under the Constitution, the main function of the Executive is to enforce laws enacted by
Congress. The former may not interfere in the performance of the legislative powers of the latter, except in
the exercise of his veto power. He may not defeat legislative enactments that have acquired the status of
laws, by indirectly repealing the same through an executive agreement providing for the performance of
the very act prohibited by said laws. In the event of conict between a treaty and a statute, the one which is
! Power VS ! The People VS ! VS De VS ! Philippines VS
0 0 0 2 0 0 3
latest in point of time shall prevail, is not applicable to the case at bar, Hechanova not only admits, but,
also, insists that the contracts adverted to are not treaties. No such justication can be given as regards
executive agreements not authorized by previous legislation, without completely upsetting the principle of
separation of powers and the system of checks and balances which are fundamental in our constitutional set
up.
As regards the question whether an executive or an international agreement may be invalidated by our
courts, sufce it to say that the Constitution of the Philippines has clearly settled it in the afrmative, by
providing that the SC may not be deprived of its jurisdiction to review, revise, reverse, modify, or afrm
on appeal, certiorari, or writ of error, as the law or the rules of court may provide, nal judgments and
decrees of inferior courts in All cases in which the constitutionality or validity of any treaty, law,
ordinance, or executive order or regulation is in question. In other words, our Constitution authorizes the
nullication of a treaty, not only when it conicts with the fundamental law, but, also, when it runs counter
to an act of Congress.

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GONZALES vs
HECHANOVA
United States vs
Ang Tang Ho
Ramon Gonzales vs
COMELEC
Jose B.L. Reyes vs
Ramon Bagatsing
People of the
Philippines vs
Loreta Gozo
Maximo Soliven vs
Ramon Makasiar
Hawaiian
Philippine Co.
versus Asociacion
de Hacenderos de
Silay-Saravia Inc.,
et al
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