Case Summary (G.R. No. L-9820)
Facts of the Case
Pedro R. Exconde was apprehended on May 5, 1954, while aboard the s.s. President Wilson, bound for Japan. He was found in possession of P5,090 in Philippine currency, in addition to U.S. $50 in cash, travelers’ checks worth $100, and a remitter’s receipt for $350. His possession of the P5,000 far exceeded the legal limit of P100 stipulated under Central Bank Circular No. 37, which mandates that outgoing passengers may only carry up to P100 in Philippine currency. As a result, a sentence was imposed on Exconde, consisting of four months of imprisonment and a fine of P100, plus costs.
Applicable Law
The relevant legislative framework includes Central Bank Circular No. 37 and Republic Act No. 265, commonly known as the Central Bank Act. Section 34 of the Central Bank Act provides penalties for violations of the law and any regulations issued by the Monetary Board. Central Bank Circular No. 37 directly addresses limits on carrying Philippine currency abroad to maintain monetary stability.
Appeal Arguments
Exconde filed an appeal arguing that Circular No. 37 was invalid. He contended that Section 34 of the Central Bank Act does not authorize the issuance of such circulars because it focuses solely on regulations related to the supervision of banking institutions. The Appellant’s second argument claimed that Section 14 of the Central Bank Act does not permit the Monetary Board to restrict the exportation of Philippine currency, suggesting that if any authority existed, it was an unlawful delegation of legislative power.
Court Analysis on Circular Validity
The court rejected Exconde’s arguments regarding the invalidity of Circular No. 37. It highlighted that Section 34 serves a broad purpose in establishing penal sanctions for violations of the entire Central Bank Act, and to conclude otherwise would permit wide-scale regulatory infractions without consequences. Furthermore, the court affirmed that the Monetary Board has the authority to promulgate regulations consistent with the objectives defined in the Central Bank Act, specifically for maintaining monetary stability and preserving the international value of the Philippine peso.
Delegation of Legislative Power
The court acknowledged that while the exclusive power to make laws rests with Congress, there is a constitutional basis for Congress to delegate authority to administrative bodies, such as the Monetary Board, to issue regulations that fulfill legislative objectives. The provisions specified in Section 14 of the Central Bank Act permit the creation of rules necessary for the Board to discharges its responsibilities effectively.
Conformity with Objectives of the Law
The judgment asserted that Circular No. 37 is congruous with the objectives of the Central Bank Act, aiming to control the money supply and preserve the peso's value against foreign currencies. The court emphasized that limitations on currency exportation are necessary to thwart depreciation effects caused by excessive outflow.
Penalties and Enforcement
The court underscored that violations of valid circulars can result in criminal charges as statutorily defined in Section 34. The legal foundation lies in the principle that regulatory violations, rooted in duly enacted legislation, are enf
...continue readingCase Syllabus (G.R. No. L-9820)
Case Citation
- Jurisprudence: 101 Phil. 1125
- G.R. No. L-9820
- Date: August 30, 1957
Parties Involved
- Plaintiff and Appellant: The People of the Philippines
- Defendant and Appellant: Pedro R. Exconde
Background of the Case
- The accused, Pedro R. Exconde, was convicted in the Court of First Instance of Manila for violating Central Bank Circular No. 37, which limits the amount of Philippine currency an outgoing passenger can carry to P100.
- The trial court imposed a sentence of four months of imprisonment, a fine of P100, and costs.
Facts of the Case
- On May 5, 1954, while aboard the s.s. President Wilson bound for Japan, Exconde was found in possession of:
- P5,090 in Philippine currency
- U.S. $50 in cash
- Travelers’ checks amounting to $100
- A Bank of America remitter’s receipt for $350
- The possession of P5,000 was unlicensed, directly violating Central Bank Circular No. 37.
Legal Framework
- Central Bank Circular No. 37: Prohibits the import and export of Philippine currency beyond specified amounts without a license.
- Section 1: Violators are subject to penal provisions.
- Section 2: Specifies limits for travelers on incoming and outgoing currency.
- Section 3: Details liability for excess amounts found with outgoing passengers.
- Section 4: Repeals inconsistent previous regulations.
- Section 5: Immediate effect of the circular.
- Republic Act No. 265 (Central Bank Act):
- Section 34: Establishes penalties for willful violations of the Act or regulations