Case Digest (G.R. No. L-21897)
Facts:
Ramon A. Gonzales v. Rufino G. Hechanova, etc., G.R. No. L-21897, October 22, 1963, Supreme Court En Banc, Concepcion, J., writing for the Court.Petitioner Ramon A. Gonzales, a rice planter (owner of 275 hectares) and president of the Iloilo Palay and Corn Planters Association, filed an original action for prohibition with preliminary injunction against respondents led by Rufino G. Hechanova, Executive Secretary, and members of a rice procurement committee (the Secretary of National Defense, the Auditor General, the Secretary of Commerce and Industry, and the Secretary of Justice). On September 22, 1963 the Executive Secretary authorized the importation of 67,000 tons of foreign rice to be purchased from private sources and created a procurement committee to implement the importation; petitioner filed his petition shortly thereafter (about September 25, 1963).
Petitioner alleged that the proposed importation was illegal because it violated Republic Act No. 2207 (prohibiting importation of rice and corn except as the President may authorize under prescribed conditions) and Republic Act No. 3452 (prohibiting importation of rice and corn by the Rice and Corn Administration or any other government agency and prescribing a government policy favoring direct purchase from local producers). He claimed he had no plain, speedy and adequate remedy other than the relief sought and asked for a writ of preliminary injunction to restrain respondents from implementing the importation, and for a permanent injunction after hearing on the merits.
Respondents filed an answer, asserted that the importation was authorized by the President as a military stockpiling measure under his powers as Commander-in-Chief (invoking Commonwealth Act No. 1, the National Defense Act), and submitted memoranda. The Court set the petition first for hearing on the injunction and then on the merits; the parties waived oral arguments and filed memoranda. This was an original action in the Supreme Court (petition for prohibition with preliminary injunction), and the Court ultimately resolved both the jurisdictional issues and the merits.
The Court declared that the Executive Secretary had no power to authorize the importation and that the authority had been exceeded and the importation was not sanctioned by law; however, for lack of the requisite majority the Co...(Pro-only)
Issues:
- Does petitioner have sufficient interest (standing) to maintain this original action for prohibition and seek injunctive relief?
- Must petitioner first exhaust administrative remedies before resorting to the Court?
- Was the Executive Secretary (and the Government acting through him) authorized to import rice for military stockpiling in the face of Republic Acts Nos. 2207 and 3452 and applicable statutes (including Commonwealth Act No. 1 and Commonwealth Act No. 138)?
- Were the alleged contracts with the Governments of Vietnam and Burma valid executive agreements that could supersede or validate the proposed importation despite the statutes?
- Should a writ of preliminary injunction iss...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)