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Ynot Vs IAC Landmark Case

Executive Order No. 626-A prohibited the inter-provincial transport of carabaos. The petitioner transported six carabaos from one province to another by boat when they were confiscated by police under the executive order. The petitioner sued for recovery of the carabaos. The regional trial court and intermediate appellate court both upheld the confiscation. The Supreme Court ruled the executive order unconstitutional. It found the transport ban did not reasonably achieve the goal of preventing slaughter of carabaos and was unduly oppressive. The order also violated due process by allowing confiscation without a hearing and delegated unlimited legislative powers to officials.

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Jonnifer Quiros
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45 views2 pages

Ynot Vs IAC Landmark Case

Executive Order No. 626-A prohibited the inter-provincial transport of carabaos. The petitioner transported six carabaos from one province to another by boat when they were confiscated by police under the executive order. The petitioner sued for recovery of the carabaos. The regional trial court and intermediate appellate court both upheld the confiscation. The Supreme Court ruled the executive order unconstitutional. It found the transport ban did not reasonably achieve the goal of preventing slaughter of carabaos and was unduly oppressive. The order also violated due process by allowing confiscation without a hearing and delegated unlimited legislative powers to officials.

Uploaded by

Jonnifer Quiros
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Jonnifer S.

Quiros
CPU College of Law

J.D. 1

Legal Writing
Atty. Solidum

A Landmark Case Digest

G.R. No. 74457


March 20, 1987
RESTITUTO YNOT, petitioner,
vs.
INTERMEDIATE APPELLATE COURT, et. al., respondents.

FACTS:
On January 13, 1984, the petitioner transported six carabaos in a pump boat from
Masbate to Iloilo when the same was confiscated by the police station commander of
Barotac Nuevo, Iloilo for the violation of Executive Order No. 626-A. The petitioner sued
for recovery, and the Regional Trial Court of Iloilo City issued a writ of replevin upon his
filing of a supersedeas bond of P12,000.00. After considering the merits of the case, the
court sustained the confiscation of the carabaos and, since they could no longer be
produced, ordered the confiscation of the bond. The court also declined to rule on the
constitutionality of the executive order, as raise by the petitioner, for lack of authority
and also for its presumed validity. The petitioner appealed the decision to the
Intermediate Appellate Court but it also upheld the ruling of RTC.
ISSUE: Whether or not E.O. 626-A is unconstitutional.
RULING:
Yes. The Supreme Court (SC) does not see how the prohibition of the inter-provincial
transport of carabaos can prevent their indiscriminate slaughter, considering that they
can be killed anywhere, with no less difficulty in one province than in another. Obviously,
retaining the carabaos in one province will not prevent their slaughter there, any more
than moving them to another province will make it easier to kill them there.
The SC further finds that the challenged measure is an invalid exercise of the police
power because the method employed to conserve the carabaos is not reasonably
necessary to the purpose of the law and, worse, is unduly oppressive. Due process is
violated because the owner of the property confiscated is denied the right to be heard in
his defense and is immediately condemned and punished. The conferment on the
administrative authorities of the power to adjudge the guilt of the supposed offender is a
clear encroachment on judicial functions and militates against the doctrine of separation
JSQ 1

Jonnifer S. Quiros
CPU College of Law

J.D. 1

Legal Writing
Atty. Solidum

of powers. There is, finally, also an invalid delegation of legislative powers to the officers
mentioned therein who are granted unlimited discretion in the distribution of the
properties arbitrarily taken. For these reasons, the SC hereby declares Executive Order
No. 626-A unconstitutional.

JSQ 2

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