Doctrine of Necessary Implication

The conferment of express power to approve a plan for stock distribution of the agricultural land of corporate owners necessarily includes the power to revoke or recall the approval of the plan. Hence, to deny the Presidential Agrarian Reform Council (PARC) such revocatory power would reduce it into a toothless agency of the Comprehensive Agrarian Reform Program (CARP), because the very same agency tasked to ensure compliance by the corporate landowner with the approved Stock Distribution Plan (SDP) would be without authority to impose sanctions for non-compliance with it (Hacienda Luisita Inc., et al v. Presidential Agrarian Reform Council, G.R. No. 171101. July 5, 2011).