G.R. No. L-2044, L-2756, L-3054, L-3055, L-3056; August 26, 1949
J. ANTONIO ARANETA, et al., petitioners, vs. RAFAEL DINGLASAN, et al., respondents.

FACTS

These consolidated petitions challenged the validity of various executive orders issued by the President under the authority of Commonwealth Act No. 671 (the Emergency Powers Act). The specific executive orders involved regulated residential rentals (EO 62), controlled exports (EO 192), appropriated funds for general government operations (EO 225), and appropriated funds for the 1949 elections (EO 226). Petitioners, facing prosecution for violating EO 62 or seeking to restrain the implementation of the other orders, argued that CA 671 had ceased to be effective, rendering the subsequent executive orders invalid.

ISSUE

Did Commonwealth Act No. 671 remain in force, thereby authorizing the President to issue the challenged executive orders after the adjournment of the regular session of Congress in 1946?

RULING

No. The Court held that Commonwealth Act No. 671 , which delegated emergency powers to the President, ceased to be operative upon the adjournment of the regular session of Congress in 1946. The Act was passed pursuant to Section 26, Article VI of the 1935 Constitution, which authorized the National Assembly to delegate emergency powers to the President for a limited period. The law itself was silent on its duration. The Court ruled that the limited period intended by the Constitution expired when Congress adjourned its regular session in 1946, as the emergency arising from the war had ended, and Congress had resumed its normal legislative functions. Consequently, executive orders issued under CA 671 before the 1946 adjournment (like EO 62) remained valid, but those issued after (EO 192, EO 225, and EO 226) were declared null and void for lack of statutory authority.

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