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Araneta v Dinglasan

84 PHIL 368
FACTS
The five cases are consolidated for all of them present the same fundamental question. Antonio
Araneta is being charged for violating EO 62 which regulates rentals for houses and lots for
residential buildings. Another case is of Leon Ma. Guerrero seeking to have a permit issued for
the exportation of his manufactured shoes. Another is of Eulogio Rodriguez seeking to prohibit
the Treasury from disbursing funds pursuant to EO 225, while another is of Antonio Barredo
attacking EO 226 which appropriated funds to hold the national elections. They all contend that
CA 671 or the Emergency Powers Act is already inoperative and that all EOs issued under said
Act also ceased
ISSUE:
Whether or not the Emergency Powers Act has ceased to have any force and effect.
RULING:
Petition is granted. We trust, also serve to answer the vehement plea that for the good of the
Nation, the President should retain his extraordinary powers as long as turmoil and other ills
directly or indirectly traceable to the late war harass the Philippines.
Article VI of the Constitution provides that any law passed by virtue thereof should be
"for a limited period." It is to be presumed that Commonwealth Act No. 671 was approved with
this limitation in view. The opposite theory would make the law repugnant to the Constitution
and is contrary to the principle that the legislature is deemed to have full knowledge of the
constitutional scope of its powers.
For Congress might not enact the repeal, and even if it would, the repeal might not
meet with the approval of the President, easier for Congress to delegate its powers than to take
them back.
Section 4 goes far to settle the legislative intention of this phase of Act No. 671. Section
4 stipulates that "the rules and regulations promulgated thereunder shall be in full force and
effect until the Congress of the Philippines shall otherwise provide."
Anomaly of nullifying each other’s actions (because two legislative bodies are
operating on it)
President Quezon to be entrusted with its execution, stated in his autobiography, "The
Good Fight," that Act No. 671 was only "for a certain period" and "would become invalid unless
reenacted." These phrases connote automatical extinction of the law upon the conclusion of a
certain period.
It is our considered opinion, and we so hold, that Commonwealth Act No. 671 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.

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