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ARANETA v. DINGLASAN

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ARANETA v. DINGLASAN
1st Emergency Power Cases
Araneta is being charged under violation of EO 62 which regulates rentals for houses and lots for
residential buildings. Dinglasan is the judge hearing the case. Araneta appealed seeking to prohibit
Dinglasan and the Fiscal from proceeding with the case. He averred that EO 62 was issued by virtue of
CA No. 671. 3 other cases were consolidated with this one. L-3055 which is an appeal by Ma. Guerrero, a
shoe exporter, against EO 192 which controls exports in the Philippines; he is seeking to have permit. L-
3054 is filed by Rodriguez to prohibit the treasury from disbursing funds [from ’49-‘50] pursuant to EO
225. L-3056 is filed by Barredo is attacking EO 226 w/c is appropriating funds to hold the national
elections. CA 671 is otherwise known as 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 or simply the Emergency Powers Act. All the
petitioners aver that CA 671 ceased to have any force and effect hence all E0s passed pursuant to it had
likewise ceased.
ISSUE: Whether or not CA 671 has ceased.
HELD: CA 671 became inoperative ex proprio vigore 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 SC is giving effect to the purpose and intention of the National
Assembly. 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adjournment of the following sessions of the Legislature, "unless sooner amended or repealed by the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 EPAs, otherwise it is lifted upon reconvening or upon early repeal.
Rodriguez vs Gella
2nd Emergency Powers Cases
Rodriguez et al seek to invalidate EO. 545 and 546 issued in 1952, the first appropriating the sum of
P37,850,500 for urgent and essential public works, and the second setting aside the sum of P11,367,600
for relief in the provinces and cities visited by typhoons, floods, droughts, earthquakes, volcanic action
and other calamities. These EO’s were pursuant to CA 671. Note that prior to Araneta vs Dinglasan,
Congress passed HB 727 intending to revoke CA 671 but the same was vetoed by the President due to
the Korean War and his perception that war is still subsisting as a fact.
ISSUE: Whether or not the EO’s are valid.
HELD: As similarly decided in the Araneta case, the EO’s issued in pursuant to CA 671 shall be rendered
ineffective. The president did not invoke any actual emergencies or calamities emanating from the last

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world war for which CA 671 has been intended. Without such invocation, the veto of the president
cannot be of merit for the emergency he feared cannot be attributed to the war contemplated in CA
671. Even if the president vetoed the repealing bill the intent of Congress must be given due weight. For
it would be absurd to contend otherwise. For "while Congress might delegate its power by a simple
majority, it might not be able to recall them except by two-third vote. In other words, it would be easier
for Congress to delegate its powers than to take them back. This is not right and is not, and ought not to
be the law." Act No. 671 may be likened to an ordinary contract of agency, whereby the consent of the
agent is necessary only in the sense that he cannot be compelled to accept the trust, in the same way
that the principal cannot be forced to keep the relation in eternity or at the will of the agent. Neither
can it be suggested that the agency created under the Act is coupled with interest.
People vs. Vera
[GR 45685, 16 November 1937]
First Division, Laurel (J): 4 concur, 2 concur in result
Facts: The People of the Philippine and the Hongkong and Shanghai Banking Corporation (HSBC), are
respectively the plaintiff and the offended party, and Mariano Cu Unjieng is one of the defendants, in
the criminal case entitled "The People of the Philippine Islands vs. Mariano Cu Unjieng, et al." (Criminal
case 42649) of the Court of First Instance (CFI) of Manila and GR 41200 of the Suprme Court. Hon. Jose
O. Vera, is the Judge ad interim of the seventh branch of the Court of First Instance of Manila, who
heard the application of Cu Unjieng for probation in the aforesaid criminal case. The information in the
said criminal case was filed with the CFI on 15 October 1931, HSBC intervening in the case as private
prosecutor. After a protracted trial unparalleled in the annals of Philippine jurisprudence both in the
length of time spent by the court as well as in the volume in the testimony and the bulk of the exhibits
presented, the CFI, on 8 January 1934, rendered a judgment of conviction sentencing Cu Unjieng to
indeterminate penalty ranging from 4 years and 2 months of prision correccional to 8 years of prision
mayor, to pay the costs and with reservation of civil action to the offended party, HSBC. Upon appeal,
the court, on 26 March 1935, modified the sentence to an indeterminate penalty of from 5 years and 6
months of prision correccional to 7 years, 6 months and 27 days of prision mayor, but affirmed the
judgment in all other respects. Cu Unjieng filed a motion for reconsideration and four successive
motions for new trial which were denied on 17 December 1935, and final judgment was accordingly
entered on 18 December 1935. Cu Unjieng thereupon sought to have the case elevated on certiorari to
the Supreme Court of the United States but the latter denied the petition for certiorari in November,
1936. The Supreme Court, on 24 November 1936, denied the petition subsequently filed by Cu Unjieng
for leave to file a second alternative motion for reconsideration or new trial and thereafter remanded
the case to the court of origin for execution of the judgment.
Cu Unjieng filed an application for probation on 27 November 1936, before the trial court, under the
provisions of Act 4221 of the defunct Philippine Legislature. Cu Unjieng states in his petition, inter alia,
that he is innocent of the crime of which he was convicted, that he has no criminal record and that he
would observe good conduct in the future. The CFI of Manila, Judge Pedro Tuason presiding, referred

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ARANETA v. DINGLASAN 1st Emergency Power Cases Araneta is being charged under violation of EO 62 which regulates rentals for houses and lots for residential buildings. Dinglasan is the judge hearing the case. Araneta appealed seeking to prohibit Dinglasan and the Fiscal from proceeding with the case. He averred that EO 62 was issued by virtue of CA No. 671. 3 other cases were consolidated with this one. L-3055 which is an appeal by Ma. Guerrero, a shoe exporter, against EO 192 which controls exports in the Philippines; he is seeking to have permit. L-3054 is filed by Rodriguez to prohibit the treasury from disbursing funds [from ’49-‘50] pursuant to EO 225. L-3056 is filed by Barredo is attacking EO 226 w/c is appropriating funds to hold the national elections. CA 671 is otherwise known as 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 or simply the Emergency Powers Act. All the petitioners aver that CA 671 ceased to have any force and effect hence all E0s passed pursuant to it had likewise ceased. ISSUE: Whether or not CA 671 has ceased. HELD: CA 671 became inoperative ex proprio vigore 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 th ...
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