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Araneta vs. Gatmaitan
GR Nos. L-8895, L-9191, April 30, 1957FACTS:
FACTS OF THE CASE
The League of Municipal Mayors of municipalities near the San Miguel Bay, betweenthe provinces of Camarines Sur and Camarines Norte, manifested in a resolution that theycondemn the operation of trawls in the said area and resolving to petition the President of thePhilippines to regulate fishing in San Miguel Bay. In another resolution, the same League of Mayors prayed that the President ban the operation of trawls in the San Miguel Bay area. Inresponse to the pleas, the President issued EO 22 prohibiting the use of trawls in San MiguelBay but the EO was amended by EO 66 apparently in answer to a resolution of the ProvincialBoard of Camarines Sur recommending the allowance of trawl-fishing during the typhoonseason only. Subsequently, EO 80 was issued reviving EO 22.Thereafter, a group of Otter trawl operators filed a complaint for injunction praying that theSecretary of Agriculture and Natural Resources and Director of Fisheries be enjoined fromenforcing said executive order and to declare the same null and void. The Court held that untilthe trawler is outlawed by legislative enactment, it cannot be banned from San Miguel Bay byexecutive proclamation and held that the EOs 22 and 66 are invalid.
W/N the President has authority to issue EOs 22, 66 and 802.
W/N the said EOs were valid as it was not in the exercise of legislative powers undulydelegated to the President
1. YES. Under sections 75 and 83 of the Fisheries law, the restriction and banning of trawlfishing from all Philippine waters come within the powers of the Secretary of Agricultureand Natural Resources. However, as the Secretary of Agriculture and Natural Resourcesexercises its functions subject to the general supervision and control of the President of the Philippines, the President can exercise the same power and authority throughexecutive orders, regulations, decrees and proclamations upon recommendation of theSecretary concerned. Hence, EOs 22,66 and 80 restricting and banning of trawl fishingfrom San Miguel Bay are valid and issued by authority of law.
2. YES. For the protection of fry or fish eggs and small immature fishes, Congress intendedwith the promulgation of the Fisheries Act, to prohibit the use of any fish net or fishingdevise like trawl nets that could endanger and deplete our supply of seafood, and to thatend authorized the Secretary of Agriculture and Natural Resources to provide byregulations and such restrictions as he deemed necessary in order to preserve theaquatic resources of the land. When the President, in response to the clamor of thepeople and authorities of Camarines Sur issued EO 80 absolutely prohibiting fishing bymeans of trawls in all waters comprised within the San Miguel Bay, he did nothing butshow an anxious regard for the welfare of the inhabitants of said coastal province anddispose of issues of general concern which were in consonance and strict conformitywith the law