Grajo, Salvador Jr. H.

Admin Law

Salvador Araneta, et al. v. Hon. Gatmaitan, et. al.

GR Nos. L-8895 and L-9191, April 30, 1957

Facts:
The League of Municipal Mayors of the municipalities near San Miguel Bay of the
provinces of Camarines Sur and Camarines Norte manifested in a resolution condemning
the operation of trawl fishing. They also petitioned to the President of the Philippines to
regulate fishing in San Miguel Bay.
In another resolution, the same League of Mayors prayed that the President ban the
operation of trawl fishing in San Miguel Bay. In response, the President issued EO 22,
prohibiting the use of trawls in San Miguel Bay but the EO was amended by EO 66,
recommending the allowance of trawl fishing during typhoon season only. Subsequently, EO
80 was issued, reviving EO 22. Thereafter, a group of Otter trawl operators filed a complaint
for injunction praying that the Secretary of Agriculture and Natural Resources and the
Director of Fisheries be enjoined from enforcing said Executive Order and to declare the
same as null and void. The Court held that until the trawler is outlawed by legislative
enactment, it cannot be banned from San Miguel Bay by executive proclamation and held
that EOs 22 and 66 are invalid.

Issues:
1) Whether or not the President has authority to issue EOs 22, 66 & 80;
2) Whether EOs 22, 66 & 80 were valid, since it was not in the exercise of
legislative powers unduly delegated to the President.

Held:
1. Yes. Under Sections 75 and 83 of the Fisheries Law, the restriction and banning
of trawl fishing from all Philippine waters come within the powers of the of the
Secretary of Agriculture and Natural Resources. However, as the latter exercises
its functions subject to the general supervision and control of the President of the
Philippines, the President can exercise the same power and authority through
executive orders, regulations, decrees and proclamations upon recommendation
of the Secretary concerned. Hence, Eos 22, 66 and 80 restricting and banning of
trawl fishing from San Miguel Bay are valid and issued by authority of law.
2. Yes. Congress intended the promulgation of the Fisheries Act to prohibit the use
of any fish net or fishing device like trawl nets that could endanger and deplete
our supply of seafood. It authorized the Secretary of Agriculture and National
Resources to provide by regulations and such restrictions as he deemed
necessary in order to preserve the aquatic resources of the land. The response of
the President to the clamor of the people and authorities of Camarines Sur was to
issued EO 80, prohibiting fishing by means of trawl in all waters within San
Miguel Bay. The President shows an anxious regard for the welfare of the
inhabitants of said coastal province and dispose of issue of general concern
which were in consonance and strict conformity with the law.