Location via proxy:   [ UP ]  
[Report a bug]   [Manage cookies]                

Ynot vs. Iac

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 2

YNOT v.

IAC
G.R. No. 74457 March 20, 1987
CRUZ, J.:

FACTS

President Marcos’s Executive Order No. 626-A decreed an absolute ban on the
inter-provincial transportation of carabao and carabeef. Transported carabao or
carabeef in violation of this order shall be confiscated and forfeited by the
government, to be distributed to charitable institutions and other similar institutions. The
Chairman of the National Meat Inspection Commission (NMIC) shall distribute the
carabeef as he may see fit. The carabaos, on the other hand, shall be given to
deserving farmers as the Director of Animal Industry (AI) may also see fit.

Restituto Ynot had transported six carabaos in a boat from the province of
Masbate to the province of Iloilo. The police confiscated these for violating EO 626-A.
Ynot filed a case for recovery, which the RTC granted upon his filing of supersede as
bond worth Php 12,000. The lower court sustained the confiscation of the carabaos,
and as they can no longer be produced, directed the confiscation of the bond. The
court refrained from ruling on the constitutionality of the executive order, on the
grounds of want of authority and presumed validity. On appeal to the Intermediate
Appellate Court, such ruling was upheld. With this, petitioner Ynot asserts that EO 626-A
is unconstitutional insofar as it authorizes outright confiscation, and that its penalty
suffers from invalidity because it is imposed without giving the owner a right to be heard
before a competent and impartial court—as guaranteed by due process and invalidly
delegated legislative power.

ISSUE

1. Whether or not Executive Order 626-A is valid

HELD

1. NO, the Supreme Court ruled that the Executive Order is not valid as it violates
due process and the delegation of legislative power. A presumption was treated
in accordance with EO 626-A, a judgment of the executive. The movement of
carabaos from one area to the other does not mean a subsequent slaughter of
the same would ensue. Ynot should be given the chance to defend himself and
explain why the carabaos are being transferred before they can be confiscated.
The Supreme Court found that the challenged measure is an invalid exercise of
the police power because the method employed to conserve the carabaos is
not reasonably necessary to the purpose of the law and, worse, is unduly
oppressive. Due process is violated because the owner of the property
confiscated is denied the right to be heard in his defense and is immediately
condemned and punished. The conferment on the administrative authorities of
the power to adjudge the guilt of the supposed offender is a clear
encroachment on judicial functions and militates against the doctrine of
separation of powers.

Also, there is a clear invalid delegation of legislative power. The manner


by which the disposition of the confiscated property clearly presents invalid
delegation by granting the officers, the Chairman and Director of the NMIC and
AI respectively, unlimited discretion. The usual standard and reasonable
guidelines that said officers must observe in making the distribution are not
present; instead, they are to proceed on it as they may see fit. This makes the
exercise prone to partiality and abuse, and even corruption.

You might also like