People v. Maceren
REITERATIONFacts
The Antecedents: On March 7, 1969, Jose Buenaventura, Godofredo Reyes, Benjamin Reyes, Nazario Aquino, and Carlito del Rosario were charged with violating Fisheries Administrative Order No. 84-1, which penalized electro fishing in fresh water fisheries. The complaint alleged that the accused used a motor banca equipped with a generator and an electrocuting device to catch fish by electric current, destroying aquatic animals. Procedural History: The municipal court quashed the complaint. The prosecution appealed, but the Court of First Instance of Laguna affirmed the dismissal. The case was elevated to the Supreme Court on appeal by the prosecution. The Petition: The prosecution argued that Administrative Orders Nos. 84 and 84-1 were validly issued under the rule-making powers granted by the Fisheries Law and related statutes, and that electro fishing was punishable thereunder.
Issue(s)
Whether Fisheries Administrative Orders Nos. 84 and 84-1, which penalize electro fishing, are valid exercises of the rule-making power of the Secretary of Agriculture and Natural Resources and the Commissioner of Fisheries. Whether the Court of First Instance of Laguna had appellate jurisdiction over the municipal court's order of dismissal.
Ruling
The Court of First Instance of Laguna's decision affirming the municipal court's order of dismissal is set aside for lack of appellate jurisdiction. The municipal court's order of dismissal is affirmed. Costs de officio.
Ratio Decidendi
On the validity of Administrative Orders Nos. 84 and 84-1: The Supreme Court held that the Secretary of Agriculture and Natural Resources and the Commissioner of Fisheries exceeded their authority in issuing Fisheries Administrative Orders Nos. 84 and 84-1, and that these orders are not warranted under the Fisheries Law. The Court reasoned that the Fisheries Law does not expressly prohibit electro fishing, and therefore, the Secretary and Commissioner are powerless to penalize it through administrative orders. The Court emphasized that the power to declare what acts constitute an offense is vested exclusively in the legislature, and this power cannot be delegated to executive officials. The administrative orders, in penalizing electro fishing, were deemed devoid of any legal basis and void ab initio. The Court noted that the subsequent enactment of Presidential Decree No. 704 expressly punishes electro fishing, recognizing the deficiency in the old Fisheries Law on this point. The Court reiterated the principle that administrative regulations must be in harmony with the provisions of the law and cannot extend or amend statutory requirements or embrace matters not covered by the statute. The Court cited precedents like People vs. Santos and State vs. Miles to support the principle that administrative bodies cannot legislate or penalize acts not expressly prohibited by law. On the appellate jurisdiction of the Court of First Instance: The Supreme Court ruled that the Court of First Instance of Laguna had no appellate jurisdiction over the case. Since the crime of electro fishing, as penalized by Administrative Order No. 84, carried a penalty of a fine not exceeding P500.00 or imprisonment of not more than six months, it fell within the concurrent original jurisdiction of inferior courts and the Court of First Instance. However, the case was filed in the municipal court of Sta. Cruz, Laguna, a provincial capital. According to Section 45 and the last paragraph of Section 87 of the Judiciary Law, orders of dismissal rendered by such municipal courts were directly appealable to the Supreme Court, not to the Court of First Instance. Therefore, the Court of First Instance's order affirming the dismissal was void for lack of jurisdiction.
Main Doctrine
Administrative regulations penalizing acts not expressly prohibited by law are void for exceeding the delegated authority of the issuing body.