YNOT v.

IAC
G.R. No. 74457
March 20, 1987

TOPIC IN CONTEXT: Tests for Valid Delegation

Facts:
In this case, the constitutionality of Executive Order No. 626-A by former President Marcos is
contested. The transfer of carabao (regardless of age, sex, physical condition, or purpose) and
carabeef across provinces was outright prohibited by the aforementioned order. The
government will collect and forfeit any carabao or carabeef that is transported in violation of this
law, and in the case of carabeef, the Chairman of the National Meat Inspection Commission
(NMIC) may decide to donate it to charitable organizations and other institutions of a like nature.
Carabaos must be distributed to deserving farmers in accordance with the Director of Animal
Industry's discretion.

Six (6) carabaos had been moved by the petitioner in a pump boat from Masbate to Iloilo. Due
to their violation of the aforementioned injunction, the police seized these. After filing a
supersedeas bond in the amount of P12,000, the RTC granted his request for recovery in his
lawsuit. Following a hearing on the merits, the lower court upheld the carabaos' confiscation
and, as they can no longer be produced, ordered the bond's forfeiture. On the grounds of a lack
of power and presumed legitimacy, it postponed making a decision about the executive order's
constitutionality.

Such a decision was sustained in an appeal to the Intermediate Appellate Court. This petition
for review on certiorari is the result. In general, the petitioner claims that EO 626-A violates the
constitution insofar as it permits outright seizure and that its punishment is illegitimate since it is
enforced without providing the owner with an opportunity to be heard before a competent and
impartial court—as required by due process.

Issue
Whether or not lower courts have authority to resolve the issue of constitutionality of legislative
measures

Ruling
YES. According to the SC, lower courts are not prohibited from deciding constitutional disputes.
According to the Constitution, we have the authority to, among other things, "review, revise,
reverse, modify or affirm on appeal or certiorari, as the law or rules of court may provide," final
judgments and decisions of lower courts in all situations regarding the constitutionality of
particular measures. "