Araneta vs Dinglasan

Facts:
Presidents of the Philippines issued Executive Orders in pursuance to the Act. No 671 which
delegates Emergency Power to the President by act of the Congress in times of war. In case at bar, there
are four EO’s involved, which are the following:
1. Executive Order No. 62, which regulates rentals for houses and lots for residential buildings.
2. Executive Order 192, promulgated on December 24, 1948, which aims to control exports from
the Philippines.
3. Executive Order 225, dated on June 15, 1949, which appropriate funds for the operation of
the Government during the period from July 1, 1949 to June 30, 1950.
4. Executive Order 226, promulgated on June 15, 1949, which appropriates P6, 000,000.00 to
defray the expenses in connection with, and incidental to the hold lug of the national elections
to be held in November, 1949.

In these cases, petitioners rest their proposition that the Emergency Power Acts (C.A. No. 671)
has ceases to have any force and effect.

Issue:
1. Whether or not the Emergency Power Acts has ceases to have any force and effect, thereby
invalidating EO’s 62, 192, 225, 226.

Ruling: Although CA No. 671 providing the delegation of Emergency Power to the President does not
expressly provides the duration of the effectiveness of such power, it is however in pursuance to the
provision of the Article VI Section 26 of the Constitution which expressly provides that emergency power
shall be for limited period only. Limited period was defined as restrictive in duration which signifies that
the Congress intended it to be temporary.
In question whether or not CA No. 671 has ceases its force an effect, the court ruled that by the time the
Congress convenes following the war, its effect has ceases and thereby having no force at all. CA 167 is
only valid and effective during the emergency and will atomically ceases upon the end of the emergency
in which it was created.

Memory Aid:
War
4 Executive Orders pursuance to CA 167
Article VI Section 26
Emergency ceases upon the end of the emergency