Statutory Construction

Midterms (Case Doctrines)

Tolentino vs. Secretary of Finance

Legislative Power

Initiative for filing of revenue, tariff or tax bills, bills authorizing an increase of public
debt, private bills and bills of local appropriation must come from the House of
Representatives for the representatives are expected to be more sensitive to the local
needs and problems.

Senators, who are elected at large, are expected to approach the same problem from the
national perspective.

Presidential certification dispenses with the requirement not only of printing but also that
of reading the bill on separate days.

Unless clause must be read in relation to except clause because the two are
coordinate clauses of the same sentence.

There may be 3 versions of the bill or revenue bill originating from the lower House:
1. From the lower House
2. From the Senate
3. From the Conference Committee

If the report of the conference committee adopting a third version of the bill was
approved by both houses, then it will be the final version, which is conclusive under the
doctrine of enrolled bill and will be submitted to the President for approval.

The requirement that no bill shall become a law unless it has passed 3 readings on
separate days and printed copies thereof in its final form have been distributed to the
members 3 days before its passage does not apply to conference committee reports.

Given the power of the senate to propose amendments, the Senate can propose its own
version even of respect to matters which are required to originate in the House.

In case of conflict between the enrolled bill and the legislative journals, it is the former
that should prevail, except as to matters that the Constitution requires to be entered in the
journals, such as the yeas and the nays of the final reading of the bill or any question at
the request of at least 1/5 of the members of the House, the objections of the President to
a vetoed bill or item, and the names of the members voting for or against overriding his
veto.

The enrolled copy of bill is conclusive not only of its provisions but also of its due
enactment.
Astorga vs. Villegas

Before an approved bill is sent to the President for his consideration as required by the
Constitution, the bill is authenticated. The system of authentication devised is the signing
by the speaker and the Senate President of the printed copy of the approved bill, certified
by the respective secretaries of the both houses to signify to the President that the bill
being presented to him has been duly approved by the legislature and is ready for
approval or rejection.

A bill originating in the House may undergo such extensive changes in the Senate, with
its power to propose or concur with amendments, that the result may be a re- writing of
the whole.

The speaker and the President of the Senate may withdraw their respective signatures
from the signed bill where there is serious and substantial discrepancy between the text of
the bill as deliberated in the legislative and shown by the journal and that of the enrolled
bill. Such withdrawal renders the bill without attestation and nullifies its status as an
enrolled bill.

Ople vs Torres

The legislative body possesses plenary power for all purposes of civil government. Any
power, deemed to be legislative by usage and tradition, is necessarily possessed by
Congress, unless the Constitution has lodged it elsewhere. Except as limited by the
Constitution, either expressly or impliedly, legislative power embraces all subjects and
extends to matters of general concern or common interest.

Arroyo vs. De Venecia

A law may not be declared unconstitutional when what has been violated in its passage
are merely internal rules of procedure of the House, in the absence of any violation of the
Constitution or of the rights of an individual. Rules of House of Congress are subject to
revocation, modification, or waiver at the pleasure of the body adopting them. They are
procedural, and with their observance, the courts have no concern. They may be waived
or disregarded by the legislative body. The mere failure to conform to parliamentary
usage will not invalidate the action taken by the body when the requisite number of
members has agreed to a particular measure.

Unless the rules of proceedings of both Houses have violated any constitutional restraints
or violate fundamental rights, and provided that there should be a reasonable relation
between the mode or method of proceedings established by the rule and the result which
is sought to be attained, the law may not be declared unconstitutional for not having been
enacted in accordance with the internal rules.

The journal is regarded as conclusive with respect to matters that are required by the
constitution to be recorded therein. With respect to the other matters, in the absence of
evidence to the contrary, the journals have also been accorded conclusive effect.
PHILJA vs. Prado

The respective rules of the Senate and the House of Representatives provide for a
conference committee. Generally, a conference committee is the mechanism for
compromising differences between the Senate and the House in the passage of a bill into
law. However, its jurisdiction is not limited to such question. There is nothing in the
Rules which limits a conference committee to a consideration of conflicting provision. It
is within its power to include in its report an entirely new provision that is not found
either in the House bill or in the Senate bill.

The aims of the Constitutional Requirement of 1 title, 1 subject rule are:

1. To prevent hodgepodge/ log-rolling legislation;
2. To prevent surprise or fraud upon the legislature, by means of provisions
in bills of which the title gave no information, and which might therefore
be overloaded and carelessly and unintentionally adopted;
3. To fairly apprise the people, through such publication of legislative
proceedings as is usually made, of the subjects of the legislation that are
being heard thereon, by petition or otherwise if they shall so desire.

The title of the bill is not required to be an index to the body of the act, or to be
comprehensive as to cover every single detail of the measure. If the title fairly indicates
the general subject, and reasonably covers all the provisions of the act, and is not
calculated to mislead the legislature or the people, there is sufficient compliance with the
constitutional requirement.

The repeal of a statute on a given subject is properly connected with the subject matter of
a new statute on the same subject; and therefore a repealing section in the new statute is
valid, notwithstanding that the title is silent on the subject.

Lidasan vs.COMELEC

The constitutional provision contains dual limitations upon the legislature. First, the
legislature is to refrain from conglomeration under one statute, of heterogeneous subjects.
Second, the title of the bill is to be couched in a language sufficient to notify the
legislators and the public and those concerned of the import of the single subject thereof.

The general rule of partial invalidity is that where part of a statute is void as repugnant to
the Constitution, while another part is valid, the valid portion, if separable from the
invalid, may stand and be enforced.

The exception to the general rule is that when parts of a statute are so mutually dependent
and connected, as conditions, considerations, inducements, or compensations for each
other, as to warrant a belief that the legislature intended them as a whole, the nullity of
one part will vitiate the rest. In making the parts of the statutes dependent, conditional, or
connected with one another, the legislature intended the statute to be carried out as a
 whole and would not have enacted it if one part is void, in which case if some parts are
unconstitutional, all the other provisions thus dependent, conditional, or connected must
fall with them.

Cawaling vs. COMELEC

Where a law amends a section or part of a statute, it suffices if reference be made to the
legislation to be amended, there being no need to state the precise nature of the
amendment.

Morales vs. Subido

The bill as passed by Congress, authenticated by the Speaker and Senate President and
approved by the President is known as the enrolled bill.

The legislative journals, and the enrolled bill are both conclusive upon the courts.
However, where there is a discrepancy between the journal and the enrolled bill, the latter
as a rule prevails over the former, particularly with respect to matters not expressly
required to be entered into the legislative journal.

The vital difference between initiating policy, often involving a decided break with the
past, and merely carrying out a formulated policy, indicates the relatively narrow limits
within which choice is rarely open to courts and the extent to which interpreting law is
inescapably making law.

Courts may not, in the guise of interpretation, enlarge the scope of a statute and include
therein situations not provided nor intended by the lawmakers. An omission at the time of
enactment, whether careless or calculated, cannot be judicially supplied however later
wisdom may recommend the inclusion.

Casco Phil. Chemical Corp. vs. Gimenez

Under the principle of the enrolled bill, the text of the act as passed and approved is
deemed importing absolute verity and is binding on the courts.

If there has been any mistake in the printing of the bill before it was certified by the
officer of the assembly and approved by the chief executive, the remedy is by amendment
by enacting a curative legislation, not by judicial decree.

And even if the statements of those who spoke reflect the views of the assembly, if the
act as passed is plain and clear, then it has to be given effect as thus enacted and not as
the individual members considered it to be.
PHILCONSA vs. Gimenez

Effect of insufficiency of title: A statute whose title does not conform to the
constitutional requirement or is not related in any manner to its subject is null and void.

In the determination of the degree of interest essential to give the requisite standing to
attack the constitutionality of a statute, the general rule is that not only persons
individually affected but also taxpayers have sufficient interest in preventing the illegal
expenditure of moneys raised by taxation and may therefore question the validity of laws
requiring expenditure of public moneys.

Maxima Realty Management and Dev. Corp. vs. Parkway Real Estate Dev. Corp.

Raises the issue as to whether an administrative rule prescribing a period issue as to

whether an administrative rule prescribing a period of 30 days to appeal a decision to the
Office of the President prevails over a Presidential Decree providing that appeal from
said agency to the office of the President is 15 days. The Court ruled that the Presidential
Decree, which is a law, prevails and the administrative rule is void.