Facts:
The petitioner is
Confederation of Coconut Farmers Organizations of the Philippines, Inc. (CCFOP) and the respondents are
His Excellency President Benigno Simeon C. Aquino III,
Acting Commissioner Richard Roger Amurao (PCGG),
Chairman Cesar L. Villanueva (GCG), and
Secretary Leila M. De Lima (DOJ); the controversy arose after the issuance of
E.O. Nos. 179 and 180 on March 18, 2015 and the petition for prohibition under Rule 65 was filed in the Supreme Court which issued a Temporary Restraining Order on June 30, 2015. The factual background traces to the imposition of the coconut levy under
R.A. No. 6260 on June 19, 1971, the pooling of collections into the Coconut Investment Fund and the issuance of receipts convertible into shares of the Coconut Investment Company, and the active roles played by the
Philippine Coconut Authority (PCA),
United Coconut Planters Bank (UCPB), and
Philippine Coconut Producers Federation, Inc. (COCOFED) in the collection, administration and investment of levy proceeds, including the acquisition of San Miguel Corporation shares; during martial law successive presidential decrees were issued including
P.D. Nos. 276, 582, 755, and
961, while
P.D. No. 1234 (November 8, 1977) remitted many special and fiduciary funds to the Treasury to be treated as Special Accounts in the General Fund (SAGF) and
P.D. No. 1468 (June 11, 1978) attempted to restore the characterization of certain levy funds as private, a provision later struck down by the Court; subsequent programs and executive issuances such as the Sagip Niyugan Program created by
E.O. Nos. 312 and 313 and the privatization and reconveyance measures of
E.O. Nos. 179 and 180 prompted litigation, and the Court in prior cases
COCOFED v. Republic,
Republic v. COCOFED, and
Pambansang Koalisyon ng mga Samahang Magsasaka at Manggagawa sa Niyugan (PKSMMN) had declared the coconut levy funds to be public in nature and invalidated provisions or acts that converted them into private assets; in the present petition CCFOP challenged the constitutionality of the assailed executive orders as a usurpation of legislative appropriation power, as an encroachment on the PCA’s statutory mandate under
P.D. No. 232, and as an intrusion on the judiciary’s exclusive authority to execute its final and executory decisions, and the Supreme Court resolved procedural questions including standing before reaching the merits and rendered judgment on August 8, 2017.
Issues:
Whether the
President gravely abused his discretion by issuing
E.O. Nos. 179 and 180 without prior legislation. Whether the
President usurped the mandate of the
PCA by arrogating to himself the power to allocate, use and administer the coconut levy funds and assets. Whether the
President violated the exclusive authority of the
judiciary to execute its final and executory decisions and thereby breached the principle of *separation of powers*.
Ruling:
Ratio:
Doctrine: