Title
Association of Philippine Coconut Desiccators vs. Philippine Coconut Authority
Case
G.R. No. 110526
Decision Date
Feb 10, 1998
PCA Resolution No. 018-93 deregulating the coconut industry was declared null and void by the Supreme Court for exceeding PCA's authority, violating due process, and undermining the regulatory framework mandated by law.
A

Case Digest (G.R. No. L-24314)

Facts:

  • Pre-Resolution Litigation
    • On November 5, 1992, seven desiccated coconut processors (APCD members) sued the PCA in the RTC Makati to enjoin issuance of licenses for new plants in “congested areas” under PCA Administrative Order No. 02, s. 1991.
    • The RTC issued a temporary restraining order on November 6, 1992, and a writ of preliminary injunction on November 25, 1992, prohibiting PCA from issuing permits to certain applicants upon posting of a ₱100,000 bond.
  • PCA Board Resolution No. 018-93
    • On March 24, 1993, the PCA Governing Board adopted Resolution No. 018-93, declaring that PCA would cease requiring licenses or permits for establishment or operation of coconut processing plants and would limit itself to registering processors for “monitoring their volumes of production” and “administration of quality standards.”
    • The full text emphasized a State policy favoring “free enterprise unhampered by protective regulations and unnecessary bureaucratic red tapes” and asserted that licensing was beyond the PCA’s chartered powers.
  • APCD’s Administrative and Judicial Relief Efforts
    • APCD appealed to the Office of the President on April 26, 1993, and sent follow-up letters on May 25 and June 2, 1993, seeking disapproval of Resolution 018-93; no response was received.
    • Meanwhile, PCA issued certificates of registration under the new resolution, enabling numerous new mills to operate.
    • On June 25, 1993, APCD filed a petition in the Supreme Court for certiorari and mandamus to annul Resolution 018-93 and compel PCA to comply with statutory licensing requirements.

Issues:

  • Whether PCA Board Resolution No. 018-93 is ultra vires as an undue exercise of legislative power by an administrative agency.
  • Whether Resolution 018-93 is arbitrary, unreasonable, and thus violative of substantive due process.
  • Whether PCA violated procedural due process by failing to consult as required under PD 1644, EO 826, and PCA Administrative Order No. 002, s. 1991.
  • Whether APCD prematurely resorted to judicial relief without exhausting administrative remedies, constituting forum-shopping.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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