GR 110526 Romero (Digest)
G.R. No. 110526, February 10, 1998.
ASSOCIATION OF PHILIPPINE COCONUT DESICCATORS, petitioner, vs. PHILIPPINE COCONUT AUTHORITY, respondent.
FACTS
The Philippine Coconut Authority (PCA) issued Board Resolution No. 018-93 dated March 24, 1993, deregulating the coconut processing plant industry. The Association of Philippine Coconut Desiccators (APCD) filed a petition for prohibition and mandamus seeking the annulment of the resolution. APCD contends that the resolution is invalid for violating the principle of non-delegability of legislative power, arguing that the PCA exercised undelegated legislative discretion and acted contrary to laws mandating it to regulate and rationalize the coconut industry.
ISSUE
Whether the PCA, in issuing Board Resolution No. 018-93 deregulating the coconut industry, acted within its validly delegated authority or constituted an invalid abdication of its regulatory power.
RULING
The dissenting opinion argues that the petition should be dismissed, holding that PCA-BR No. 018-93 is a valid exercise of delegated legislative power. The authority to issue the resolution is found in Section 3(a) of P.D. No. 232, which empowers the PCA “to formulate and adopt a general program of development for the coconut and other palm oil industry.” This grant of authority is repeated in subsequent amendatory laws. The delegation satisfies the completeness and sufficient standard tests. The law provides adequate standards such as “to promote accelerated growth and development of the coconut and other palm oil industry” and “rapid integrated development and growth,” which are sufficient to guide the PCA. The resolution, which limits PCA to registering processors for monitoring production volumes and administering quality standards, is in harmony with these objectives and the constitutional mandate for the State to adopt measures to make locally produced goods competitive. The deregulation policy is a response to changing global economic circumstances, overproduction, and world market demand, and represents a substantive form of regulation through registration and monitoring, not an abdication of power. The wisdom of the deregulation measure is a policy question for the legislature and the administrative agency, not the court.
