Case Digest (G.R. No. L-65295) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 685 Phil. 295 (G.R. Nos. 147036-37, 147811, April 10, 2012), multiple farmer organizations (PKSMMN, COIR, Buklod, PAKISAMA, CARET, PKSK), legislator Loreta Ann Rosales, individuals (David, Faustino, Concepcion, Royandoyan, Romero Jr., Sabio, Carpio, Pasaley, Encallado, Piliin) sought to declare various martial law–era decrees and Executive Orders unconstitutional insofar as they pertain to the collection, administration, and disposition of coco-levy funds. Beginning with R.A. 6260 (1971) which imposed a P0.55 levy per 100kg of copra to capitalize the Coconut Investment Fund, President Marcos subsequently issued P.D. 276 (1973) creating the Coconut Consumers Stabilization Fund with a P15 levy, P.D. 582 (1974) establishing the Coconut Industry Development Fund with a P0.20 levy, P.D. 755 (1975) approving the acquisition of a bank (later UCPB) for farmers, P.D. 961 (1976) and its amendment P.D. 1468 (1978) codifying the coco-levies as private property of farmers, and P.D. 1699 ( Case Digest (G.R. No. L-65295) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Legislative and executive measures establishing coco-levy funds
- Republic Act No. 6260 (June 19, 1971) created the Coconut Investment Fund (CI Fund) with a levy of ₱0.55 per 100 kg of copra, administered by the Coconut Investment Company (CIC).
- Presidential Decree (P.D.) 276 (August 20, 1973) established the Coconut Consumers Stabilization Fund (CCS Fund) with a ₱15-per-100 kg copra levy; unused balance to revert to the CI Fund.
- P.D. 582 (November 14, 1974) created the Coconut Industry Development Fund (CID Fund), initial capital of ₱100 million by the Philippine Coconut Authority (PCA), permanent levy of ₱0.20 per kg copra, to be administered by the Philippine National Bank (PNB).
- P.D. 755 (1975) approved acquisition of First United Bank (later United Coconut Planters Bank – UCPB) by the PCA for industry credit policy.
- P.D. 961 (July 14, 1976) codified coconut industry laws, created the Coconut Industry Investment Fund (CIIF) from surplus levies, declared coco-levy funds private under Article III, Section 5.
- P.D. 1468 (June 11, 1978) reiterated private ownership of coco-levy funds.
- P.D. 1699 (1980) suspended levy collections; P.D. 1841 (1981) revived collections as the Coconut Industry Stabilization Fund (CIS Fund) for developmental programs.
- Subsequent executive orders and litigation
- Executive Order (E.O.) 312 (November 2000) created the Sagip Niyugan Program, a ₱1 billion fund from sale of coco-levy–acquired assets, managed by a presidential committee.
- E.O. 313 (November 2000) constituted the Coconut Trust Fund with San Miguel Corporation shares as capital, managed by a presidentially appointed committee, and excluded from Sandiganbayan sequestration.
- President Gloria Macapagal-Arroyo suspended E.O.s 312 and 313 (January 26, 2001).
- Petitions filed: G.R. Nos. 147036-37 (April 24, 2001) challenging E.O.s 312 and 313 and Article III, Section 5 of P.D. 1468; G.R. No. 147811 (2001) challenging Section 2 of P.D. 755 and Article III, Section 5 of P.D.s 961 and 1468.
Issues:
- Procedural issues
- Whether certiorari under Rule 65 was the proper remedial remedy.
- Whether petitioners had legal standing to maintain the actions.
- Substantive issues
- Whether the coco-levy funds are public funds.
- Whether Section 2 of P.D. 755 is unconstitutional.
- Whether Article III, Section 5 of P.D. 961 and P.D. 1468 is unconstitutional.
- Whether E.O. 312 is unconstitutional.
- Whether E.O. 313 is unconstitutional.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)