Friday, November 15, 2013

Pesigan v. Angeles 129 SCRA 174

FACTS: Anselmo Pesigan and Marcelo Pesigan were transporting 26 carabaos and a calf in the evening of April 2, 1982 from Camarines Sur to Batangas. They had three certificates: 1) health certificate from provincial veterinarian; 2) permit to transfer/transport from the provincial commander; and 3) three certificates of inspections. However, despite of securing the said certificates, the carabaos and calf were confiscated by the provincial veterinarian and town’s police station commander while passing through Camarines Norte. The confiscation was made pursuant to EO 626-A which prohibits transportation of carabaos and carabeef from one province to another.

ISSUE: W/N EO 626-A dated October 25, 1980 is enforceable before publication in Official Gazette on June 14, 1982

HELD: No. The incident happened on April 2, 1982 while the EO’s publication only happened 2 months after. Pursuant to RAC and ART 2 of the Civil Code, law takes effect only15 days after its publication. The word “law” in NCC 2 contemplates circulars, regulations, etc which prescribe penalties and of general application.

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