Araneta v Dinglasan, Delegation of Powers

Facts: 1. The petitions challenged the validity of executive orders issued by

virtue of CA No. 671 or the Emergency Powers Act. CA 671 declared a state of
emergency as a result of war and authorized the President to promulgate
rules and regulations to meet such emergency. However, the Act did not fix
the duration of its effectivity.
2.
EO 62 regulates rentals for houses and lots for residential buildings.
The petitioner, Araneta, is under prosecution in the CFI for violation of the
provisions of this EO 62 and prays for the issuance of the writ of prohibition.
3.
EO 192, aims to control exports from the Philippines. Leon Ma. Guerrero
seeks a writ of mandamus to compel the Administrator of the Sugar Quota
Office and the Commissioner of Customs to permit the exportation of shoes.
Both officials refuse to issue the required export license on the ground that
the exportation of shoes from the Philippines is forbidden by this EO.
4.
EO 225, which appropriates funds for the operation of the Government
during the period from July 1, 1949 to June 30, 1950, and for other purposes
was assailed by petitioner Eulogio Rodriguez, Sr., as a tax-payer, elector, and
president of the Nacionalista Party. He applied for a writ of prohibition to
restrain the Treasurer of the Philippines from disbursing the funds by virtue of
this EO.
5. Finally, EO 226, which appropriated P6M to defray the expenses in
connection with the national elections in 1949. was questioned by Antonio
Barredo, as a citizen, tax-payer and voter. He asked the Court to prevent "the
respondents from disbursing, spending or otherwise disposing of that amount
or any part of it."
ISSUE: Whether or not CA 671 ceased to have any force and effect
YES. The Act fixed a definite limited period. The Court held that it became
inoperative when Congress met during the opening of the regular session on
May 1946 and that EOs 62, 192, 225 and 226 were issued without authority
of law . The session of the Congress is the point of expiration of the Act and
not the first special session after it.
Executive Orders No. 62 (dated June 21, 1947) regulating house and lot
rentals, No. 192 (dated December 24, 1948) regulating exports, Nos. 225 and
226 (dated June 15,1949) the first appropriation funds for the operation of the
Government from July 1, 1949 to June 30, 1950, and the second appropriating
funds for election expenses in November 1949, were therefore declared null
and void for having been issued after Act No. 671 had lapsed and/or after the
Congress had enacted legislation on the same subjects. This is based on the

language of Act 671 that the National Assembly restricted the life of the
emergency powers of the President to the time the Legislature was prevented
from holding sessions due to enemy action or other causes brought on by the
war.