Angeles vs philippine international trading corp.

PITC issued Administrative Order No. SOCPEC 89-08-01 under which applications to the PITC for
importation from the Peoples Republic of China must be accompanied by a viable and confirmed
export program of Philippine products. PITC barred Remington and Firestone from importing
products from China on the ground that they were not able to comply with the requirement of the
said administrative order. Thereafter they filed a petition for prohibition and mandamus against the
said order of PITC in which the trial court upheld and declared to be null and void for being
unconstitutional. The court contends further authority to process and approve applications for
imports SOCPEC and to issue rules and regulations pursuant to LOI 144 has already been repealed
by EO 133 issued on February 27, 1987. Hence, the PITC filed a certiorari seeking the reversal of
the said decision.
ISSUE: Whether or not PITCs Administrative Order 89-08-01 is valid.
HELD: The Supreme Court held that PITC is empowered to issue such order; nevertheless, the said
AO is invalid within the context of Article 2 of the New Civil Code. The Court cited Tanada vs Tuvera
which states that all statues including those of local application and private laws shall be published
as condition for their effectivity, which shall begin 15 days after publication in the Official Gazette or a
newspaper of general circulation unless a different effectivity date is fixed by the legislature. The AO
under consideration is one of those issuances which should be published for its effectivity since it is
punitive in character.