Coco levy rules: Scamming farmers not once, but thrice?

REPUBLIC Act 11524, the "Coconut Farmers and Industry Trust Fund Act," took effect on March 13, 2021. To manage the consolidated coconut levy collections currently amounting to at least P76 billion, the law created the Trust Fund Management Committee (TFMC), composed of the Departments of Finance (DoF), Budget and Management (DBM) and Justice (DoJ). The TFMC is tasked with drafting the implementing rules and regulations (IRR) governing its management of the consolidated trust fund. While RA 11524 is silent on who approves the proposed rules, the three agencies mentioned appear bent on passing their own draft through a joint memorandum circular.

Critical "process" issues need to be raised: Why the limited time (one week) for submission of stakeholders' comments and the undue haste in issuing the IRR? The Supreme Court has ruled that the trust fund is a "public fund held in trust by the government for the exclusive benefit of the coconut farmers and the industry." For this Fund that will finance economic and social programs for desperately poor coconut farmers, will genuine public hearings and consultations on its proper administration be undertaken? How will the Executive satisfy the demand for public transparency and protect the interests of the Fund's beneficial owners and trustors - the country's 3.5 million coconut farmers and farm workers?