G.R. No. 30783, August 27, 1929
JUAN B. ALEGRE, petitioner-appellee, vs. THE INSULAR COLLECTOR OF CUSTOMS, respondent-appellant.

FACTS

Petitioner Juan B. Alegre, engaged in the production and export of abaca (Manila hemp), applied to the Insular Collector of Customs for a permit to export 100 bales of abaca to England without a certificate from the Fiber Standardization Board. The Collector denied the permit, citing the requirement under the Administrative Code, as amended by Act No. 3263, that exported fibers must be inspected, graded, and certified by the Board. Alegre filed a petition for mandamus in the Court of First Instance of Manila, arguing that the relevant provisions (Sections 1772 and 1244 of the Administrative Code) were unconstitutional as an invalid delegation of legislative power. The lower court ruled in favor of Alegre, declaring the provisions void and ordering the Collector to allow the export without the Board’s certificate. The Collector appealed.

ISSUE

Whether the provisions of the Administrative Code, as amended, which require the inspection, grading, and certification of fibers by the Fiber Standardization Board prior to export, constitute an unconstitutional delegation of legislative power.

RULING

NO. The Supreme Court reversed the lower court’s decision and dismissed the petition. The Court held that the law (Act No. 2380, as amended) does not delegate legislative power but merely confers administrative authority to implement the law’s clear intent. The Legislature validly prescribed that all fibers for export must be inspected, graded, and baled. The Fiber Standardization Board was created to carry out these administrative details, such as establishing specific standards and procedures, which the Legislature itself could not practically perform. This is a permissible delegation of administrative execution, not legislative authority. The Court distinguished cited U.S. cases on interstate commerce, noting the Philippines’ distinct constitutional context. The law is a valid exercise of police power to regulate the fiber industry and ensure quality standards for export.