Philippine Tobacco Institute, Inc. v. Secretary of Health

A tobacco industry trade organization challenged the legality of an administrative order issued by an executive agency under authority delegated to the agency by Republic Act 7394.  The administrative order prescribed the manner of placing a legislatively mandated health warning on cigarette and cigar packaging, requiring, among other things, that the health warning appear on the front and back panels of packaging and occupy at least twenty-five percent of each panel.  The trial court held that portions of the order exceeded the authority granted to the agency by the Act, finding that the altered wording of the warning and the requirement that the warning should be placed on two panels of the packaging rather than in a single "conspicuous place" were invalid.  Here, the Appellate Court upheld the finding that the administrative order's alteration of the Act's wording of the warning was invalid.  However, the Court overturned the finding that the warning placement requirement was invalid, noting that the regulation corresponded to the Act and that the agency possessed discretionary authority to implement the purpose of the law in an effective manner within the guidelines set by the legislature.