Case Digest (G.R. No. 74457)
Facts:
In Restituto Ynot v. Intermediate Appellate Court, petitioner Restituto Ynot transported six carabaos by pump boat from Masbate to Iloilo on January 13, 1984, when they were seized by the police station commander of Barotac Nuevo, Iloilo, for violating Executive Order No. 626-A, which imposed an absolute ban on interprovincial movement of carabaos and carabeef and mandated their summary confiscation. Ynot sought recovery via replevin in the Regional Trial Court (RTC) of Iloilo City, posting a P12,000.00 supersedeas bond. The RTC, after finding against him on the merits and noting that the animals could not be produced, ordered forfeiture of the bond and declined to rule on the order’s constitutionality. The Intermediate Appellate Court affirmed. Ynot then filed a petition for certiorari with the Supreme Court, challenging the measure on due process, separation of powers, and improper delegation grounds under the then-applicable 1973 Constitution.Issues:
- Does Executive Order
Case Digest (G.R. No. 74457)
Facts:
- Executive Order No. 626-A
- Promulgated by President Marcos on October 25, 1983, to amend Executive Order No. 626.
- Prohibited the interprovincial transport of any carabao, regardless of age, sex, condition or purpose, and of carabeef; prescribed immediate confiscation and forfeiture of violations, with distribution of carabeef to charitable institutions and live carabaos to deserving farmers at the discretion of designated authorities.
- Events Leading to Litigation
- On January 13, 1984, petitioner Restituto Ynot transported six carabaos by pumpboat from Masbate to Iloilo; the police station commander of Barotac Nuevo confiscated the animals for violating EO 626-A.
- Ynot filed a replevin action in the Regional Trial Court of Iloilo City; he posted a P12,000.00 supersedeas bond. The RTC sustained the confiscation, ordered the bond forfeited, and declined to rule on the order’s constitutionality.
- The Intermediate Appellate Court affirmed the RTC decision. Ynot then filed a petition for review on certiorari before the Supreme Court, challenging EO 626-A as unconstitutional for lack of due process and improper delegation of legislative power.
Issues:
- Whether Executive Order No. 626-A violates the Due Process Clause by authorizing summary confiscation of property without notice or hearing.
- Whether the order exceeds the President’s legislative powers under Amendment 6 of the 1973 Constitution.
- Whether EO 626-A improperly delegates legislative power to executive officials in directing the disposition of confiscated property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)