G.R. No.

74457
March 20, 1987

Restituto Ynot, Petitioner vs. Intermediate Appellate Court, respondent.

Facts:
Restituto Ynot (petitioner) filed for a petition for recovery after he was caught
transporting six carabaos, which were later confiscated pursuant to Executive Order No. 626-A.
Petitioner contends the constitutionality of the executive order which authorizes the outright
confiscation of the carabao or carabeef being transported across provincial boundaries, the
invalidity of the penalty impose for not being granted the opportunity to be heard before a
competent and impartial court as guaranteed by the right to due process and the improper
exercise of legislative power by the former Pres. Marcos under Amendment No. 6.
Issue:
Whether or not E.O. No. 626-A is constitutional.

Held: The Supreme Court held that E.O. No. 626-A is unconstitutional. It is an invalid exercise
of the Police power of the state for the methods employed in order to conserve the carabaos is
not reasonably necessary to the purpose of the law and unduly oppressive for it complies to the
test of the lawful subject but does not comply with the test of the lawful method. The prohibition
of the interprovincial transport of carabaos has not been proven to prevent the indiscriminate
slaughter.
Petitioner was also denied of the right to be heard upon the imposition of a punishment right
when the carabaos were confiscated. The administrative authorities also committed an
encroachment of judicial functions violating the doctrine of separation of powers upon doing so,
knowing that the imposition of a proper punishment must be dealt with by the courts.
An invalid delegation of legislative powers for the Executive Order is evident when, by virtue of
Amendment No. 6, he was given the authority to exercise legislative functions when a matter
required immediate exigency.