A statutory enactment is a written law set down by a body of legislature or by

single legislator. A statute is an act of the legislature as an organized body, expressed

in the form, and passed according to the procedure, required to constitute it as part of
the law of the land. Statutes enacted by the legislature are those passed by the
Philippine commission, the Philippine Legislature, the Batasang Pambansa, and the
Congress of the Philippines. Laws which are of the same category of binding force as
statutes are precedential decrees issued by the President in the exercise of his
legislative power during the period of martial law under the 1973 Constitution and
executive orders issued by the president in the exercise of his legislative power during
the revolutionary period under the freedom constitution.

While Executive Orders are “acts of the president providing for rules of a general
or permanent character in the implementation or execution of constitutional or statutory
powers” (Sec.2, Book III, Title I, Chap.2, 1987 Administrative Code). EO 292 or the law
instituting the Administrative Code of 1987 was enacted and signed by President
Corazon Aquino when she was a revolutionary government President. Under the 1973
and Freedom Constitutions, the President of the Philippines used to exercise legislative
power in the form of Presidential decrees and executive orders, respectively, which
remains valid until repealed.

According to father Joaquin Bernas, a constitutionalist and Jesuit priest, EO 292

is an executive order of President Aquino which she issued while she still had legislative
powers before congress became operative. Therefore, the facts above are to be
considered that EO 292 is a statutory enactment. It is said that presidents have their
legislative power to make Presidential decrees that are valid and it is considered in the
time of President Aquino and have effect on the Constitution and was signed in July 25,
1987.