FIRST EMERGENCY

POWERS CASES, 84 Phil.

368
 
 G.R. No. L-2044             August 26, 1949
J. ANTONIO ARANETA, petitioner,
vs.
RAFAEL DINGLASAN, Judge of First Instance of
Manila, and JOSE P. BENGZON, Fiscal of City of
Manila, respondents.

G.R. No. L-2756             August 26, 1949

J. ANTONIO ARANETA and GREGORIO
VILLAMOR, petitioners,
vs.
EUGENIO ANGELES, Fiscal of City of
Manila, respondent.
** Involved in these cases is Executive Order No. 62,
which regulates rentals for houses and lots for residential
buildings.
 G.R. No. L-3055 August 26, 1949

LEON MA. GURRERO, petitioner,

vs.
THE COMMISSIONER OF CUSTOMS and THE
ADMINISTRATOR, SUGAR QUOTA OFFICE,
DEPARTMENT OF COMMERCE AND INDUSTRY,
respondents.

** relates to Executive Order No. 192, which aims to

control exports from the Philippines
 G.R. No. L-3054 August 26, 1949

EULOGIO RODRIGUEZ, Sr., por si y como

Presidente del Partido Nacionalista, recurrente,
vs.
EL TESORERO DE FILIPINAS, recurrido.

** Involved in this case is Executive Order No. 225,

which appropriates funds for the operation of the
Government of the Republic of the Philippines during the
period from July 1, 1949 to June 30, 1950, and for other
purposes.
 G.R. No. L-3056 August 26, 1949

ANTONIO BARREDO, in his own behalf and on

behalf of all taxpayers similarly situated,
petitioner,
vs.
THE COMMISSION ON ELECTIONS, THE
AUDITOR GENERAL and THE INSULAR
TREASURER OF THE PHILIPPINES, respondents.
** relates to Executive Order No. 226, which appropriates
P6,000,000 to defray the expenses in connection with, and
incidental to, the hold lug of the national elections to be
held in November, 1949.
FAC T S
 Commonwealth Act (CA) No. 671 otherwise known as AN ACT

.
DECLARING A STATE OF TOTAL EMERGENCY or simply the
Emergency Powers Act was enacted by the National Assembly (NA)
which authorized the President to promulgate rules and regulations to
meet such emergency in view of the state of world war in 1941.

 CA 671 did not expressly fix the term of its effectiveness, although Sec 3
thereof provides “the President shall as soon as practicable upon the
convening of the Congress report thereto all the rules and regulations
promulgated by him under the powers herein granted.”
FAC T S
 By authority vested by CA 671, then Pres. Roxas issued
.
Executive Order 62 which provided for the regulation of
the rentals of residential lots and buildings. By the same
authority, his successor, Pres. Quirino issued Executive
Orders 192, 225 and 226 providing for the appropriation
of public funds in the operation of the national
government and the conduct of the 1949 elections, and the
control of exports.
 The petitions challenge the validity of executive orders
of the President avowedly issued in virtue of CA 671.

.
 Antonio Araneta is being charged for allegedly violating
of Executive Order 62 which regulates rentals for
houses and lots for residential buildings. Araneta
appealed seeking to prohibit Judge Dinglasan and the
Fiscal from proceeding with the case. He averred that
EO 62 was issued by virtue of Commonwealth Act (CA)
No. 671 which he claimed ceased to exist, hence, the
EO has no legal basis.
FAC T S
 Leon Ma. Guerrero, a shoe exporter, appealed against EO 192

.
which controls exports in the Philippines; he is seeking to have
permit issued to him.

 Eulogio Rodriguez appealed to prohibit the treasury from

disbursing funds pursuant to EO 225.

 The petitioners in each cases aver that Commonwealth Act (CA)

671, is already inoperative and that all Executive Orders issued
pursuant to said CA had likewise ceased.
ISSUE
Whether or not
COMMONWEALT
H ACT 671 has
ceased.
RULING
Yes. CA 671, which granted emergency powers to the
president, became inoperative when Congress met in
regular session on May 25, 1946, and that Executive
Orders Nos. 62, 192, 225 and 226 were issued without
authority of law.

In setting the first regular session of Congress instead

of the first special session which preceded it as the point of
expiration of the Act, the Supreme Court is giving effect to
the purpose and intention of the National Assembly.
 RULING
In a special session, the Congress may “consider general
legislation or only such subjects as he (President) may designate.”
Such acts were to be good only up to the corresponding dates of
adjournment of the following sessions of the Legislature, “unless
sooner amended or repealed by the National Assembly.” Even if
war continues to rage on, new legislation must be made and
approved in order to continue the Emergency Powers Act,
otherwise it is lifted upon reconvening or upon early repeal.
 RULING
Furthermore, it is clear from Sec 3 of CA 671 that the legislature
intended to limit the duration of the Act when it provided that
there was to be only one meeting of Congress at which the
President was to give an account of his trusteeship. Moreover,
giving much weight on the statements of Pres. Quezon in his
autobiography (considering his part in the passage and in the
carrying out of the law), it was held that CA 671 was enacted with
the specific view of the inability of the National Assembly to
meet. Hence, the sole reason for the enactment of CA 671 was the
inability for the Congress to function; such emergency period
should thus end with the convening of that body.
THANK YOU!!