GARCIA VS EXECUTIVE SECRETARY, 211 SCRA 219

FACTS: The President issued an EO which imposed, across the board, including crude oil and other oil
products, additional duty ad valorem. The Tariff Commission held public hearings on said EO and submitted a
report to the President for consideration and appropriate action. The President, on the other hand issued an
EO which levied a special duty of P0.95per liter of imported crude oil and P1.00 per liter of imported oil
products.

ISSUE: Whether or not the President may issue an EO which is tantamount to enacting a bill in the nature of
revenue-generating measures.

RULING: The Court said that although the enactment of appropriation, revenue and tariff bills is within the
province of the Legislative, it does not follow that EO in question, assuming they may be characterized as
revenue measure are prohibited to the President, that they must be enacted instead by Congress. Section 28
of Article VI of the 1987 Constitution provides:The Congress may, by law authorize the President to fix tariff
rates and other duties or imposts The relevant Congressional statute is the Tariff and Customs Code of the
Philippines and Sections 104 and 401, the pertinent provisions thereof.

Page 1 of 1