Case Summary (G.R. No. L-21897)
Key Dates
• September 22, 1963 – Executive Secretary’s authorization of rice importation.
• September 25, 1963 – Filing of the prohibition petition.
• October 22, 1963 – Decision rendered by the Supreme Court.
Applicable Law
• Republic Act No. 2207 (1959) – Prohibits importation of rice and corn by any person or government agency, except when President authorizes in case of national emergency certified by the National Economic Council.
• Republic Act No. 3452 (1962) – Prohibits the Rice and Corn Administration or any other government agency from importing rice and corn; affirms policy of purchasing directly from local producers.
• Commonwealth Act No. 1 (National Defense Act) – Presidential authority as Commander-in-Chief; general defense policy subject to congressional legislation.
• Commonwealth Act No. 138 – Preference for locally produced materials in government procurements.
Petitioner’s Legal Standing
• Statutory Policy Right – RA 3452 declares it government policy to buy directly from local growers; petitioner qualifies as a producer entitled to supply the Government.
• Taxpayer Interest – as a landowner and producer, petitioner is also a taxpayer and may challenge unauthorized public expenditure.
• Conclusion – sufficient personality and interest to maintain prohibition and injunction proceedings.
Exhaustion of Administrative Remedies
• General Rule – must exhaust administrative remedies before judicial relief.
• Exceptions Applied – controversy is purely legal; act is patently illegal or beyond jurisdiction; Secretary acts as alter-ego of the President unless disapproved; urgency of judicial intervention.
• Court’s Holding – petitioner need not exhaust administrative remedies.
Statutory Prohibitions on Rice Importation
• Scope of RA 2207 – unlawful for any “person, association, corporation or government agency” to import rice and corn; exception only by presidential authorization under specified conditions.
• Scope of RA 3452 – explicitly bars the Rice and Corn Administration or any government agency from importing rice and corn; leaves importation to private parties upon payment of taxes.
• Interpretation – “government agency” includes all branches and instrumentalities of government; statutes therefore apply equally to direct government importations.
Government vs. Government Agency
• “Government” – entity through which political authority is exercised (national, provincial, municipal).
• “Government instrumentality/agency” – corporations or bodies owned or controlled by government but with separate legal personality.
• Conclusion – both government and its agencies are bound by prohibitions in RA 2207 and RA 3452.
National Defense and Presidential Authority
• Respondents’ Theory – as Commander-in-Chief, President may import rice for military stockpile under Commonwealth Act No. 1.
• Court’s Analysis – Section 2 of CA 1 outlines general defense policy; not self-executing; requires implementing legislation.
• Statutory Framework – RA 3452 already authorizes accumulation of buffer stocks by the Rice and Corn Administration under specified conditions; no delegation for direct importation bypassing statutory requirements.
• Conclusion – military necessity does not override or amend prohibitory statutes; statutory scheme provides alternative means for national reserve.
Contracts with Vietnam and Burma
• Alleged Executive Agreements – government contracts to purchase rice from Viet Nam and Burma executed in October 1963.
• Respondents’ Argument – executive agreem
Case Syllabus (G.R. No. L-21897)
Factual and Procedural Background
- On September 22, 1963, the Executive Secretary authorized the importation of 67,000 tons of foreign rice and appointed a Rice Procurement Committee to implement it.
- Petitioner Ramon A. Gonzales, a substantial rice planter and president of the Iloilo Palay and Corn Planters Association, filed an original petition for prohibition with preliminary injunction on September 25, 1963.
- He alleged respondents acted “without jurisdiction or in excess of jurisdiction” in importing rice, in violation of Republic Act No. 3452 (which he claimed amended or repealed RA 2207).
- Petitioner sought a writ of preliminary injunction restraining the importation, and after answers, oral arguments, and memoranda, both the injunction incident and merits were set for hearing.
Issues Presented
- Does petitioner have the requisite interest and personality (standing) to maintain the action?
- Must petitioner exhaust administrative remedies before seeking judicial relief?
- Are Republic Acts 2207 and 3452 applicable to the proposed importation by a government agency?
- Can the President or his subordinates override those statutes under Commonwealth Act No. 1’s national defense provisions?
- Are the alleged rice‐purchase contracts with Viet Nam and Burma valid executive agreements that prevail over domestic law?
- Should a writ of preliminary injunction issue to restrain the proposed importation?
I. Standing of the Petitioner
- RA 3452 declares government policy to purchase rice and corn directly from local tenants, farmers, growers, producers, and landowners.
- As a planter of 275 hectares and president of a growers’ association, petitioner is entitled to supply the Government under RA 3452.
- Public funds to purchase rice come principally from taxation; as a taxpayer, petitioner has sufficient personality and interest to challenge alleged unlawful disbursement.
II. Exhaustion of Administrative Remedies
- The general exhaustion rule does not apply when:
- The question is purely legal.
- The challenged act is patently illegal or exceeds jurisdiction.
- The respondent i