154. Araneta v Gatmaitan G.R. Nos.

L-8895, L-9191, April 30, 1957

(Topic: Complete in itself)

FACTS:
The League of Municipal Mayors of municipalities near the San Miguel Bay, between
the provinces of Camarines Sur and Camarines Norte, manifested in a resolutionthat they
condemn the operation of trawls in the said area and resolving to petitionthe President of the
Philippines to regulate fishing in San Miguel Bay. In anotherresolution, the same League of
Mayors prayed that the President ban the operationof trawls in the San Miguel Bay area. In
response to the pleas, the President issuedEO 22 prohibiting the use of trawls in San
Miguel Bay but the EO was amended byEO 66 apparently in answer to a resolution of the
Provincial Board of Camarines Surrecommending the allowance of trawl-fishing during the
typhoon season only.Subsequently, EO 80 was issued reviving EO 22 Thereafter a group of
Ottertrawloperators filed a complaint for injunction prayingthat the Secretary of Agriculture and
Natural Resources and director of Fisheries beenjoined from enforcing said executive order and
to declare the same null and void. The Court held that until the trawler is outlawed by legislative
enactment, it cannotbe banned from San Miguel Bay by executive proclamation and held that
the Eos 22and 66 are invalid.
ISSUES:
Whether or not the said EOs were valid as it was not in the exercise of legislative powers
unduly delegated to the President.
HELD:
YES. The Court holds that the EOs are valid. Congress provided under the Fisheries Act
that a.) It is unlawful to take or catch fry or fish eggs in the waters of the Phil and b.) it
authorizes Sec. of Agriculture and Nat. Resources to provide regulations/ restrictions as may be
deemed necessary. The Act was complete in it and leaves it to the Sec. to carry into effect
its legislative intent. The Pres. did nothing but show an anxious regard for the welfare of the
inhabitants and dispose of issues of gen. concern w/c were in consonance and strict conformity
with law.