Title
Universal Corn Products, Inc. vs. Rice and Cord Board
Case
G.R. No. L-21013
Decision Date
Aug 17, 1967
A Filipino-owned corporation challenged the retroactive application of a law prohibiting alien employment in the rice and corn industry, claiming it violated due process and equal protection. The Supreme Court upheld the law, ruling it applied prospectively and was a valid exercise of police power to protect national interests.

Case Digest (G.R. No. L-21013)

Facts:

Universal Corn Products, Inc., et al. v. Rice and Corn Board, et al., G.R. No. L-21013, August 17, 1967, Supreme Court En Banc, Fernando, J., writing for the Court.

Petitioners (Universal Corn Products, Inc. and several alien employees as co-petitioners) sought declaratory relief in the trial court challenging the Rice and Corn Board's interpretation of Resolution No. 10 in connection with Section 2-A of Commonwealth Act No. 108, as implemented under Republic Act No. 3018. The amended petition filed February 8, 1961 alleged that the Board promulgated Resolution No. 10 on November 21, 1960 and that one of its provisions prohibited employment of non-citizens in Filipino-owned establishments engaged in lines of activity covered by RA 3018 except for technical personnel authorized by the President. Universal Corn Products alleged it was wholly Filipino-owned and engaged in the regulated lines and that it employed over 200 Filipinos but also several alien executives and supervisors who had been in its employ long before RA 3018 and Resolution No. 10.

Petitioners asserted that applying the Board’s construction would effectively require dismissal of these alien employees and would operate retroactively and unconstitutionally by depriving them of their means of livelihood without due process and by denying equal protection. They therefore asked the court to declare the construction and its application unlawful and to rule that the alien employees could remain in petitioner's employ.

Respondents (the National Rice and Corn Board, its chairman and members) answered on March 9, 1961, admitting the factual allegations but denying the legal conclusions. They maintained that upon passage of RA 3018 and issuance of the regulation employment of aliens in the regulated industry became unlawful regardless of the date of employment and that preexisting contracts had become legally impossible to perform. They defended the measure as a valid exercise of the State’s police power and also pleaded that declaratory relief was improper and there was no cause of action.

The trial court (Judge Guillermo Torres, Pasig, Rizal) dismissed the amended petition by judgment dated August 6, 1962....(Pro-only)

Issues:

  • Is the Rice and Corn Board’s construction of Resolution No. 10 and Section 2-A of Commonwealth Act No. 108 retroactive in effect so as to invalidate existing employment relationships?
  • If not retroactive, does the construction and application of the statute and resolution deprive the alien employees of due process or equal protection and the...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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