Title
Gonzales vs. Hechanova
Case
G.R. No. L-21897
Decision Date
Oct 22, 1963
Gonzales, a rice planter, challenged 1963 rice importation, asserting it violated Republic Acts 2207 and 3452. Court ruled importation illegal, overriding President’s authority and invalidating Vietnam/Burma contracts, affirming domestic law supremacy.

Case Digest (G.R. No. L-21897)
Expanded Legal Reasoning Model

Facts:

  • Authorization of Rice Importation
  • On September 22, 1963, the Executive Secretary authorized the importation of 67,000 tons of foreign rice to be purchased from private sources.
  • A rice procurement committee, composed of the Secretaries of National Defense, Commerce and Industry, Justice, and the Auditor General, was created to implement the importation.
  • Petition for Prohibition and Injunction
  • On September 25, 1963, Ramon A. Gonzales (petitioner), a rice planter and president of the Iloilo Palay and Corn Planters Association, filed an original action for prohibition with preliminary injunction in the Supreme Court.
  • Petitioner alleged that the importation was “without jurisdiction or in excess of jurisdiction” under Republic Act No. 3452 (which amends or repeals RA 2207) and that he had no plain, speedy, or adequate remedy at law. He sought:
    • A writ of preliminary injunction restraining respondents from implementing the importation.
    • A permanent injunction after full hearing.
  • Respondents filed their answer; hearings on the injunction and on the merits were held, and memoranda were submitted. Parties waived further oral argument on the merits.

Issues:

  • Does petitioner have sufficient interest (standing) to maintain the petition?
  • Must petitioner exhaust administrative remedies before invoking judicial relief?
  • Are Republic Act Nos. 2207 and 3452, and Commonwealth Acts Nos. 1 and 138, applicable to and prohibitive of the proposed importation, even for military stockpiling?
  • Do the executive agreements (contracts) with Vietnam and Burma validly override the statutory prohibitions?
  • Should a writ of preliminary injunction issue to prevent the importation pending final decision?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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