G.R. No. L-21897 October 22 1963 [Executive Agreements]
FACTS:
Exec. Secretary Hechanova authorised the importation of
foreign rice to be purchased from private sources. Gonzales filed a petition
opposing the said implementation because RA No. 3542 which allegedly repeals or
amends RA No. 2207, prohibits the importation of rice and corn "by the
Rice and Corn Administration or any other government agency."
Respondents alleged that the importation permitted in RA
2207 is to be authorized by the President of the Philippines, and by or on
behalf of the Government of the Philippines. They add that after enjoining the
Rice and Corn administration and any other government agency from importing
rice and corn, S. 10 of RA 3542 indicates that only private parties may import
rice under its provisions. They contended that the government has already
constitute valid executive agreements with Vietnam and Burma, that in case of
conflict between RA 2207 and 3542, the latter should prevail and the conflict
be resolved under the American jurisprudence.
ISSUE:
W/N the executive agreements may be validated in our courts.
RULING:
No. The Court is not
satisfied that the status of said tracts as alleged executive agreements has
been sufficiently established. Even assuming that said contracts may properly
considered as executive agreements, the same are unlawful, as well as null and
void, from a constitutional viewpoint, said agreements being inconsistent with
the provisions of Republic Acts Nos. 2207 and 3452. Although the President may,
under the American constitutional system enter into executive agreements
without previous legislative authority, he may not, by executive agreement,
enter into a transaction which is prohibited by statutes enacted prior thereto.
Under the
Constitution, the main function of the Executive is to enforce laws enacted by
Congress. He may not interfere in the performance of the legislative powers of
the latter, except in the exercise of his veto power. He may not defeat
legislative enactments that have acquired the status of law, by indirectly
repealing the same through an executive agreement providing for the performance
of the very act prohibited by said laws.
