New Coast Hotel v. Securities

Summary

New Coast Hotel, Inc. became foreign-majority owned in 2003 but failed to file required SEC Form F-101 under the Foreign Investments Act. The SEC discovered this violation in 2014 during an articles of incorporation amendment review and imposed administrative penalties totaling PHP621,444.86. New Coast challenged the penalties claiming prescription and laches, arguing the SEC should have discovered the violation earlier through routine filings. The Supreme Court affirmed the SEC's authority to impose penalties, ruling that administrative violations under the Foreign Investments Act are imprescriptible since no statutory limitation period exists, and that the SEC was not barred by laches since it acted immediately upon discovery. The Court emphasized that courts cannot create prescription periods where none exist in law, and that the SEC's penalty power derives from its statutory administrative authority rather than civil causes of action.