Iloilo Palay and Corn Planters Association, Inc. v. Feliciano
REITERATIONFacts
The Antecedents: On December 26, 1964, the Chairman and General Manager of the Rice and Corn Administration (RCA) urged the President to import 595,400 metric tons of rice due to a shortage, pursuant to a National Economic Council (NEC) resolution. The President submitted this to the cabinet, which approved the importation on December 28, 1964. On January 4, 1965, the President designated the RCA to undertake the importation, and an invitation to bid was announced for February 1, 1965. Procedural History: The Iloilo Palay and Corn Planters Association, Inc., and Ramon A. Gonzales (as a taxpayer) filed a petition seeking to restrain the RCA Chairman from conducting the bidding and proceeding with the importation, arguing it violated Republic Act (RA) 3452 and lacked appropriation. This Court granted a writ of preliminary injunction upon posting of a P50,000 bond. The Petition: Petitioners contended that RA 3452 prohibits government importation of rice, even with an NEC certification of national emergency. Respondents argued that RA 2207, which permits government importation in emergencies, still stands.
Issue(s)
Whether Republic Act No. 3452 impliedly repealed Republic Act No. 2207, thereby prohibiting government importation of rice. Whether the importation of rice by the government, despite the provisions of Republic Act No. 3452, is illegal due to the absence of a specific appropriation law.
Ruling
The petition is dismissed, and the writ of preliminary injunction is dissolved. The Court found that Republic Act No. 3452 does not impliedly repeal Republic Act No. 2207, and that the government agency involved has the power to finance the importation.
Ratio Decidendi
On the issue of implied repeal between Republic Act No. 3452 and Republic Act No. 2207: The Court held that Republic Act No. 3452 does not impliedly repeal Republic Act No. 2207. While Section 10 of RA 3452 prohibits government agencies from importing rice and corn and leaves importation to private parties, Section 2 of RA 2207 allows the President to authorize government importation in cases of existing or imminent shortage of such gravity as to constitute a national emergency, upon certification by the National Economic Council. The Court reasoned that the repealing clause in RA 3452 is not express but conditional, requiring a conflict between the laws. It found no irreconcilable inconsistency, as RA 2207 addresses national emergencies, while RA 3452 pertains to normal times. The Court emphasized that implied repeals are not favored and require absolute incompatibility, which was not present here. The legislative intent, as evidenced by Senate debates on a subsequent bill, also supported the continued existence of RA 2207 for emergency importations. The Court also clarified that Section 12 of RA 3452, which authorizes the President to declare a rice and corn emergency and conduct raids, refers to artificial shortages due to hoarding, not actual scarcity requiring importation. On the issue of appropriation: The Court ruled that the Rice and Corn Administration (RCA) has the power to finance the importation. Under Republic Act No. 663, the National Rice and Corn Corporation (NARIC) was authorized to borrow money to carry out its objectives. RA 3452 transferred the functions and powers of NARIC to the RCA, including the power to borrow money under Section 3(e) of RA 663. Therefore, the RCA possessed the authority to secure the necessary funds to finance the contemplated importation.
Main Doctrine
Republic Act No. 3452, which prohibits government agencies from importing rice and corn and leaves importation to private parties, does not impliedly repeal Republic Act No. 2207, which allows the President to authorize government importation in cases of national emergency certified by the National Economic Council. The two laws can be reconciled as they apply to different circumstances: RA 3452 governs normal times, while RA 2207 addresses national emergencies.