Case Digest (G.R. No. 206629)
Facts:
Restituto Ynot v. Intermediate Appellate Court, the Station Commander, Integrated National Police, Barotac Nuevo, Iloilo and the Regional Director, Bureau of Animal Industry, Region IV, Iloilo City, G.R. No. 74457, March 20, 1987, the Supreme Court En Banc, Cruz, J., writing for the Court.The case arose from Executive Order No. 626‑A, promulgated October 25, 1983, which amended Executive Order No. 626 to prohibit the interprovincial transport of any carabao or carabeef and prescribed forfeiture of such animals or meat to government authorities for distribution by designated officers. The Order took effect immediately.
On January 13, 1984, petitioner Restituto Ynot transported six carabaos by pump boat from Masbate to Iloilo; the animals were seized by the police station commander of Barotac Nuevo, Iloilo, as violative of EO 626‑A. Ynot filed an action for recovery in the Regional Trial Court (RTC) of Iloilo City and, upon posting a supersedeas bond of P12,000.00, obtained a writ of replevin. After trial on the merits the RTC sustained the confiscation and, because the animals could not be produced, ordered forfeiture of the supersedeas bond; the RTC declined to pass on the constitutionality of EO 626‑A, citing lack of authority and the presumption of validity.
Petitioner appealed to the Intermediate Appellate Court (IAC), which affirmed the RTC’s disposition. Petitioner then filed a petition for review on certiorari to the Supreme Court challenging EO 626‑A as unconstitutional for (a) depriving owners of property without due process by authorizing confiscation without prior hearing or judicial trial, and (b) representing an improper exercise of legislative power under Amendment No. 6, 1973 Constitution. He also argued that the penal and forfeiture scheme amounted to usurpation of judicial power and an impermissible delegation of legislative authority.
The case reached the Court by petition for review on certiorari. The Court considered prior pronouncements such as Pesigan v. Angeles and United States ...(Subscriber-Only)
Issues:
- Do lower courts have authority to resolve constitutional questions and does this Court have jurisdiction to review such determinations?
- Does Executive Order No. 626‑A violate the constitutional guarantee of due process by authorizing summary confiscation of carabaos or carabeef without prior notice and a judicial hearing?
- Is EO 626‑A a valid exercise of the police power or of the President’s legislative authority under Amendment No. 6, 1973 Constitution, and does it unlawfully delegate legislative or judicial functions?
- Is the police station commander who enforced EO 626‑A lia...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)