1) The USAFFE Veterans Association sued to invalidate the 1950 Romulo-Snyder Agreement between the Philippines and US governments, whereby the Philippines agreed to return $35 million provided by the US for the Philippine army.
2) The court dismissed the complaint, upholding the validity of the Romulo-Snyder Agreement. It found that the Philippine President had authority to enter the agreement and the Philippine Congress subsequently ratified it through appropriations.
3) While the agreement was not formally a treaty requiring Senate ratification, the court recognized that executive agreements can be valid international accords so long as the negotiating parties act within their authority.
1) The USAFFE Veterans Association sued to invalidate the 1950 Romulo-Snyder Agreement between the Philippines and US governments, whereby the Philippines agreed to return $35 million provided by the US for the Philippine army.
2) The court dismissed the complaint, upholding the validity of the Romulo-Snyder Agreement. It found that the Philippine President had authority to enter the agreement and the Philippine Congress subsequently ratified it through appropriations.
3) While the agreement was not formally a treaty requiring Senate ratification, the court recognized that executive agreements can be valid international accords so long as the negotiating parties act within their authority.
1) The USAFFE Veterans Association sued to invalidate the 1950 Romulo-Snyder Agreement between the Philippines and US governments, whereby the Philippines agreed to return $35 million provided by the US for the Philippine army.
2) The court dismissed the complaint, upholding the validity of the Romulo-Snyder Agreement. It found that the Philippine President had authority to enter the agreement and the Philippine Congress subsequently ratified it through appropriations.
3) While the agreement was not formally a treaty requiring Senate ratification, the court recognized that executive agreements can be valid international accords so long as the negotiating parties act within their authority.
1) The USAFFE Veterans Association sued to invalidate the 1950 Romulo-Snyder Agreement between the Philippines and US governments, whereby the Philippines agreed to return $35 million provided by the US for the Philippine army.
2) The court dismissed the complaint, upholding the validity of the Romulo-Snyder Agreement. It found that the Philippine President had authority to enter the agreement and the Philippine Congress subsequently ratified it through appropriations.
3) While the agreement was not formally a treaty requiring Senate ratification, the court recognized that executive agreements can be valid international accords so long as the negotiating parties act within their authority.
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USAFFE VETERANS ASSOCIATION, INC. vs.
THE The complaint rested on plaintiff's three propositions: first,
TREASURER OF THE PHILIPPINES, ET AL. that the funds to be "returned" under the Agreement were funds appropriated by the American Congress for the DOCTRINE: Philippine army, actually delivered to the Philippine Government and actually owned by said Government; ART. VII. Section 21. No treaty or international second, that U.S. Secretary Snyder of the Treasury, had no agreement shall be valid and effective unless authority to retake such funds from the P.I. Government; concurred in by at least two-thirds of all the Members and third, that Philippine foreign Secretary Carlos P. of the Senate. Romulo had no authority to return or promise to return the FACTS: In October 1954, the USAFFE Veterans aforesaid sums of money through the so-called Romulo- Associations Inc. (Usaffe), prayed in its complaint before the Snyder Agreement. Manila court of first instance that the Romulo-Snyder Agreement (1950) whereby the Philippine Government The defendants moved to dismiss, alleging Governmental undertook to return to the United States Government in ten immunity from suit. But the court required an answer, and annual installments, a total of about 35-million dollars then heard the case merits. Thereafter, it dismissed the advanced by the United States to, but unexpanded by, the complaint, upheld the validity of the Agreement and National Defense Forces of the Philippines be annulled, that dissolved the preliminary injunction i had previously payments thereunder be declared illegal and that issued. The plaintiff appealed. defendants as officers of the Philippine Republic be ISSUE: Whether the Romulo-Snyder Agreement is void. restrained from disbursing any funds in the National Treasury in pursuance of said Agreement. Said Usaffe HELD: There is no doubt that President Quirino approved Veterans further asked that the moneys available, instead of the negotiations. And he had power to contract budgetary being remitted to the United States, should be turned over loans under Republic Act No. 213, amending the Republic to the Finance Service of the Armed Forces of the Act No. 16. The most important argument, however, rests Philippines for the payment of all pending claims of the on the lack of ratification of the Agreement by the Senate of veterans represented by plaintiff. the Philippines to make it binding on this Government. On this matter, the defendants explain as follows: That the agreement is not a "treaty" as that term is used in In the leading case of Altman vs, U. S., 224, U. S. 583, it the Constitution, is conceded. The agreement was never was held that "an international compact negotiated between submitted to the Senate for concurrence (Art. VII, Sec. 10 the representatives of two sovereign nations and made in (7). However, it must be noted that treaty is not the only the name and or behalf of the contracting parties and form that an international agreement may assume. For the dealing with important commercial relations between the grant of the treaty-making power to the Executive and the two countries, is a treaty both internationally although as Senate does not exhaust the power of the government over an executive agreement it is not technically a treaty international relations. Consequently, executive agreements requiring the advice and consent of the Senate. may be entered with other states and are effective even without the concurrence of the Senate. It is observed in this Nature of Executive Agreements. connection that from the point of view of the international law, there is no difference between treaties and executive Executive Agreements fall into two classes: (1) agreements agreements in their binding effect upon states concerned as made purely as executive acts affecting external relations long as the negotiating functionaries have remained within and independent of or without legislative authorization, their powers. "The distinction between so-called executive which may be termed as presidential agreements and (2) agreements" and "treaties" is purely a constitutional one agreements entered into in pursuants of acts of Congress, and has no international legal significance". which have been designated as Congressional-Executive Agreements. There are now various forms of such pacts or agreements entered into by and between sovereign states which do not The Romulo-Snyder Agreement may fall under any of these necessarily come under the strict sense of a treaty and two classes, for precisely on September 18, 1946, Congress which do not require ratification or consent of the legislative of the Philippines specifically authorized the President of body of the State, but nevertheless, are considered valid the Philippines to obtain such loans or incur such international agreements. indebtedness with the Government of the United States, its agencies or instrumentalities.
Even granting, arguendo, that there was no legislative
authorization, it is hereby maintained that the Romulo- Snyder Agreement was legally and validly entered into to conform to the second category, namely, "agreements entered into purely as executive acts without legislative authorization." This second category usually includes money agreements relating to the settlement of pecuniary ratification thereof, which places the question the validity claims of citizens. It may be said that this method of out of the Court's reach, no constitutional principle having settling such claims has come to be the usual way of been invoked to restrict Congress' plenary power to dealing with matters of this kind. appropriate funds-loan or no loan. Such considerations seems persuasive; indeed, the Agreement was not submitted to the U.S. Senate either; but Petition denied. we do not stop to check the authorities above listed nor test the conclusions derived therefrom in order to render a definite pronouncement, for the reason that our Senate Resolution No. 153 practically admits the validity and binding force of such Agreement. Furthermore, the acts of Congress Appropriating funds for the yearly installments necessary to comply with such Agreements constitute a