ARANETA vs.

DINGLASAN
G.R No. L-2044. Aug 26, 1949
MENDOZA, J.:

FACTS:
1. Multiple petitions (which were consolidated in this case) challenged the validity of EO’s of the
President avowedly issued in virtue of Commonwealth Act 671 1“Emergency Powers Act”

2. The law was by virtue of Section 23 of Art 6 of the Constitution providing that in times of war or
national emergency, the congress (by law) can delegate legislative powers to the Pres for a
“limited period”. The reasoning behind this being the inability of 2National Assembly to meet in
sessions due to ongoing war.

3. It was mentioned in the case that Act 671 does not fix a period of effectiveness and by way of
3
contemporaneous construction, the author of the law stated the law “would become invalid
unless reenacted”.

4. The court decided that the limiting period of the act 671 is so long as the congress is unable to
meet and legislate due to the ongoing war, and that the validity of Act 671 terminates as soon as
the Congress is able to meet and carry on their duties.

ISSUE:
WHETHER OR NOT the President had the authority to promulgate EO 62,192,225,226 by virtue of
Commonwealth Act 671.

RULING:
The EO’s promulgated by Pres under Act 671 BEFORE the regular session of Congress took place is valid.
But the EO’s promulgated after the regular session of congress are invalid (EO 192,225,226). The regular
session to have been held May 25, 1946.

Relevant laws:
Commonwealth 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

Questions:
Is act no 671 not repealed due to the fact that it was enacted for the purpose of response to the needs created during a time of war (ww2;
enacted 1941) and even enters in section 1 mentioning this. By way of accessories follow the principal, does Act 671 not get extinguished
simultaneously with when ww2 was declared ended in 1945? Making this law inactive during the time of this case in 1949.

1
Act 671 was enacted in the year 1941 which was during WW2.
2
Legislative body during those times instead of congress.
3
contemporaneous construction is the construction placed upon the statute by an executive or administrative
officer called upon to execute or administer such statute.