G.R. No. 175220 - Dagan vs. Philippine Racing Commission

Directive and guidelines
On 11 August 2004, the Philippine Racing Commission (Philracom) issued a directive requiring the Manila Jockey Club, Inc. (MJCI) and the Philippine Racing Club, Inc. (PRCI) to draft Club House Rules addressing Equine Infectious Anemia (EIA) and to rid their facilities of infected horses, pursuant to Department of Agriculture Administrative Order No. 5 (28 March 1994).
On 17 September 2004, Philracom issued guidelines for the monitoring and eradication of EIA, mandating blood sampling and Coggins testing of all racehorses.

Reaction and proceedings
Petitioners (eight racehorse owners) refused compliance, claiming lack of prior consultation, absence of official guidelines at the time of sampling, and no documented EIA cases to justify testing.
MJCI and PRCI proceeded with testing; noncompliant horses were banned from races, denied license renewal, and evicted from stables or transferred to isolation.
Petitioners sought intervention from the Office of the President, which directed Philracom to investigate. Upon inaction, they filed for injunctive relief in the Regional Trial Court (RTC) of Makati, obtaining a temporary restraining order (TRO) on 11 November 2004.
The RTC dissolved the TRO, denied the writ of injunction for lack of valid grounds, deemed the issues moot as most owners complied, and upheld the guidelines as a valid exercise of police power.
The Court of Appeals (CA) affirmed the RTC decision on 27 October 2006, citing Philracom’s exclusive jurisdiction under Presidential Decreto (P.D.) No. 420 and P.D. No. 8, and found the controversy moot.
Petitioners elevated the case to the Supreme Court via certiorari, alleging grave abuse of discretion, due process violations, ultra vires rule-making, and improper delegation by Philracom.

Legality of administrative issuances
Whether Philracom’s directive and subsequent guidelines satisfied the requisites for valid administrative issuances: legislative authorization, prescribed procedure, scope of authority, and reasonableness.
Whether the unsigned, undated guidelines violated due process, publication requirements, or exceeded Philracom’s rule-making powers.

Delegation and agency authority
Whether Philracom validly exercised its rule-making power under P.D. No. 420 and properly instructed MJCI and PRCI to formulate Club House Rules without unlawfully delegating its authority.
Whether MJCI and PRCI exceeded the powers granted in their respective congressional franchises by enforcing the EIA testing directive.