22 Sep 2016, 8:57 a.m.

Araneta v Dinglasan
G.R. No. L-2044 August 26, 1949
Tuason, J.:

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.