G.R. No. L-6266 - Rodriguez Sr. vs. Gella

Commonwealth Act No. 671 ("Declaring a state of total emergency as a result of war involving the Philippines") was approved on December 16, 1941, authorizing the President to promulgate rules and regulations to meet such emergency during the existence thereof.
The Act was passed pursuant to Section 26, Article VI of the 1935 Constitution, which permits the Congress to authorize the President, for a limited period and subject to restrictions, to promulgate rules and regulations during times of war or national emergency.
Prior rulings (August 26, 1949) held divergent views: five justices opined the Act ceased to operate on May 25, 1946 or June 9, 1945, whereas others held that the powers delegated to the President were withdrawn as to matters where Congress had legislated or demonstrated readiness to act.

Petitioners sought to invalidate Executive Orders Nos. 545 and 546, issued November 10, 1952, appropriating P37,850,500 for urgent public works and P11,367,600 for relief due to natural calamities.
Petitioners argued these orders exceeded presidential emergency powers as delegated under Commonwealth Act No. 671.

Congress passed House Bill No. 727 repealing all Emergency Powers Acts, including Commonwealth Act No. 671, though the President vetoed the bill; thus it did not become law.
Despite the veto, the Congress, via a concurrent resolution and petition from about 70 legislators, urged the President to release funds for reconstruction and relief.
The President justified his exercise of emergency powers citing failure of Congress to appropriate funds in special session and impending emergencies due to world conditions and participation in the Korean War.

Petitioners asserted that (a) the emergency as defined by Commonwealth Act No. 671 terminated with World War II; (b) the Act’s delegation of powers was only valid for the emergency caused by that war; (c) new executive orders appropriating funds exceeded authority; and (d) congressional repeal was ineffective without presidential concurrence.
Respondents maintained that emergencies persist due to continued post-war effects and other national calamities; hence, the President retained emergency powers.
The Court was tasked to determine the validity of Executive Orders Nos. 545 and 546 and the continuing force of Commonwealth Act No. 671.

Whether Commonwealth Act No. 671 and the emergency powers delegated under it were still in force as of 1952.
Whether the President, under the purported continuing emergency powers, could validly appropriate public funds by Executive Orders Nos. 545 and 546 for public works and calamity relief.
Whether Congress’s passage of House Bill No. 727—despite presidential veto—effectively repealed Commonwealth Act No. 671 and withdrew emergency powers delegated to the President.
The nature and limits of the constitutional delegation of legislative power to the President in times of war or national emergency, specifically concerning duration, withdrawal, and scope.