This document summarizes a Supreme Court case from the Philippines regarding the constitutionality of a section of Republic Act No. 4670. Three public school officials were charged with violating this law. They argued the law was unconstitutional as it delegated legislative powers to courts by not specifying the duration of imprisonment. The court agreed, finding Section 32 unconstitutional as it did not provide minimum or maximum imprisonment periods, giving courts too much discretion without legislative guidance. While courts can exercise discretion within limits set by law, this section set no limits, equivalent to delegating legislative authority to courts.
This document summarizes a Supreme Court case from the Philippines regarding the constitutionality of a section of Republic Act No. 4670. Three public school officials were charged with violating this law. They argued the law was unconstitutional as it delegated legislative powers to courts by not specifying the duration of imprisonment. The court agreed, finding Section 32 unconstitutional as it did not provide minimum or maximum imprisonment periods, giving courts too much discretion without legislative guidance. While courts can exercise discretion within limits set by law, this section set no limits, equivalent to delegating legislative authority to courts.
This document summarizes a Supreme Court case from the Philippines regarding the constitutionality of a section of Republic Act No. 4670. Three public school officials were charged with violating this law. They argued the law was unconstitutional as it delegated legislative powers to courts by not specifying the duration of imprisonment. The court agreed, finding Section 32 unconstitutional as it did not provide minimum or maximum imprisonment periods, giving courts too much discretion without legislative guidance. While courts can exercise discretion within limits set by law, this section set no limits, equivalent to delegating legislative authority to courts.
This document summarizes a Supreme Court case from the Philippines regarding the constitutionality of a section of Republic Act No. 4670. Three public school officials were charged with violating this law. They argued the law was unconstitutional as it delegated legislative powers to courts by not specifying the duration of imprisonment. The court agreed, finding Section 32 unconstitutional as it did not provide minimum or maximum imprisonment periods, giving courts too much discretion without legislative guidance. While courts can exercise discretion within limits set by law, this section set no limits, equivalent to delegating legislative authority to courts.
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G.R. No.
L-45127 May 5, 1989
PEOPLE OF THE PHILIPPINES, represented by the Provincial Fiscal of Leyte, petitioner,
vs. HON. JUDGE AUXENCIO C. DACUYCUY, CELESTINO S. MATONDO, SEGUNDINO A, CAVAL and CIRILO M. ZANORIA, respondents.
REGALADO, J.:
FACTS: In a complaint filed by the Chief of Police of Hindang, Leyte, the private respondents Celestino S. Matondo, Segundino A. Caval, and Cirilo M. Zanoria, public school officials of Leyte, were charged before the Municipal Court of Hindang, thereof for violation of Republic Act No. 4670.
Private respondents filed for certiorari and prohibition with preliminary injunction before the former Court of First Instance of Leyte, Branch VIII, to restrain the Municipal Judge, Provincial Fiscal and Chief of Police of Hindang, Leyte from proceeding with the trial of said Criminal Case No. 555 upon the ground that the former Municipal Court of Hindang had no jurisdiction over the offense charged. An additional ground that the facts charged do not constitute an offense since the penal provision, which is Section 32 of said law, is unconstitutional for It constitutes an undue delegation of the legislative power, the duration of the penalty of imprisonment being solely left to the discretion of the court as if the latter were the legislative department of the Government.
Respondent Judge rendered the afforested challenged decision holding in substance that Republic Act No. 4670 is valid and constitutional but cases for its violation fall outside of the jurisdiction of municipal and city courts, and remanding the case to the former Municipal Court of Hindang, Leyte only for preliminary investigation.
Petitioner filed a motion for reconsideration of the lower court’s decision but the same was limited only to the portion thereof which sustains the validity of Section 32 of Republic Act No. 4670.
ISSUE: WON Whether Section 32 of said Republic Act No. 4670 is undue delegation of legislative power
HELD: Yes. In the case under consideration, the respondent judge erroneously assumed that since the penalty of imprisonment has been provided for by the legislature, the court is endowed with the discretion to ascertain the term or period of imprisonment. We cannot agree with this postulate. It is not for the courts to fix the term of imprisonment where no points of reference have been provided by the legislature. What valid delegation presupposes and sanctions is an exercise of discretion to fix the length of service of a term of imprisonment which must be encompassed within specific or designated limits provided by law, the absence of which designated limits well constitute such exercise as an undue delegation, if not-an outright intrusion into or assumption, of legislative power.
Section 32 of Republic Act No. 4670 provides for an indeterminable period of imprisonment, with neither a minimum nor a maximum duration having been set by the legislative authority. The courts are thus given a wide latitude of discretion to fix the term of imprisonment, without even the benefit of any sufficient standard, such that the duration thereof may range, in the words of respondent judge, from one minute to the life span of the accused. Irremissibly, this cannot be allowed. It vests in the courts a power and a duty essentially legislative in nature and which, as applied to this case, does violence to the rules on separation of powers as well as the non-delegability of legislative powers. On the foregoing considerations, and by virtue of the separability clause in Section 34 of R.A. No. 4670, the penalty of imprisonment provided in Section 32 thereof should be, as it is hereby, declared unconstitutional.
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