Statutory Construction

Case List
SY 2018-2019

Introduction

Caltex v. Palomar, G.R. No. L-19650, 29 September 1966

I. Statutes

Tolentino v. Secretary of Finance, G.R. No. 115455, 25 August 1994 EVAT constitutionality; separation of powers precludes sc from deciding on
internal procedure of congress

Arroyo v. De Venecia, G.R. No. 127255, 14 August 1997 Enrolled bill- courts can’t inquire into matters of internal procedure of congress-separation of
powers
Alvarez v. Guingona, G.R. No. 118303, 31 January 1996 Substitution bill from senate allowed as long as it withholds action while the appropriations
bill is still in house of reps
Casco v. Gimenez, G.R. No. L-17931, 28 February 1963 Enrolled bill doctrine- if there has been any mistake in the printing of the bill, the remedy is by
amendment or curative legislation
Mabanag v. Vito, G.R. No. L-1123, 5 March 1947 Irregularities in proposal
binding upon the courts
of amendments; enrolled bill- A duly authenticated bill imports absolute verity and is

Morales v. Subido, G.R. No. L-29658, 27 February 1969
Astorga v. Villegas, G.R. No. L-23475, 30 April 1974
United States v. Pons, G.R. No. L-11530, 12 August 1916
With respect to matters not expressly required to be entered in the journal, the enrolled bill prevails
in the event of any discrepancy
Withdrawal of signatures=as if the law was not passed
Court refuses to inquire into the veracity of the journals when they are clear and explicit;
separation of powers

Delegation of powers- power of the purse lies in Congress as a bicameral body alone, lump sum
Belgica v. Ochoa, G.R. No. 208560, 19 November 2013 discretionary funds are unconstitutional
Araullo v. Aquino, G.R. No. 209287, 3 February 2015 Heads of the three departments can only augment budget within their departments; otherwise,
encroachment upon the other depts

In the exercise of the power of judicial review, the function of the court is merely to check,
Marcos v. Manglapus, G.R. No. 88211, 15 September 1989 not to supplant the executive. Part of residual powers of the pres ang protection of general
Ocampo v. Enriquez, G.R. No. 225973, 8 November 2016 welfare of the people

Test of a valid The overbreadth doctrine applies when a statute needlessly restrains
even constitutionally guaranteed rights; in overbreadth analysis,
ordinance: White Light Corporation v. Manila, G.R. No. 122846, 20 January 2009 petitioners are allowed to raise the rights of third parties
1) must not
contravene the Resident Marine Mammals of the Protected Seascape Tanon Strait v. Reyes, G.R. No. 180771, 21 April
constitution or any In cases where the statute seems to be in conflict with the constitution but a construction that is in harmony with the constitution
statute 2015 is also possible, that construction should be preferred. Basic precept in statcon: a statute should be interpreted in harmony with PD 87 still in force
2) must not be unfair the constitution and that the spirit rather than the letter of the law determines its construction. For that reason, a statute must be
or oppressive read acc to spirit and intent Void for vagueness doctrine- a statute is not rendered uncertain and void merely
3) must not be partial
or discriminatory
Estrada v. Sandiganbayan, G.R. No. 148560, 19 November 2001 because general terms are used therein, or because of the employment of the terms
without defining them, much less do we have to define every word we use
4) must not prohibit Central Bank Employees Association, Inc. v. Banko Sentral ng Pilipinas, G.R. No. 148208, 15 December
but may regulate
trade 2004 Equal protection; reqs of valid classification: (1) must be based on substantial distinctions which make for real differences, (2)
must be germane to the purpose of the law, (3) must not be limited to existing conditions only, (4) must apply equally to all
5) must be general members of the same class
and consistent with
public policy
6) must not be
Tañada v. Tuvera, G.R. No. L-63915, 29 December 1986
Customs Memorandum Order- no need for publication in OG since it
unreasonable Yaokasin v. Commissioner of Customs, G.R. No. 84111, 22 December 1989 only addresses particular persons or a particular class of persons-its
subordinates- customs collectors-assumption is it has been
Philippine Internal Trading Corp. v. COA, G.R. No. 132593, 25 June 1999 circularized to all concerned
DBM-CCC mandating the agency to issue the necessary guidelines to implement RA6758-null and void cause no
publication
II. Construction and Interpretation

Caltex v. Palomar, G.R. No. L-19650, 29 September 1966

Aisporna v. Court of Appeals, G.R. No. L-39419, 12 April 1989 Noscitur a sociis-the word agent-dapat paid

Separation of powers-the legislature cannot lawfully declare the collection of income tax of a
Endencia v. David, G.R. No. L-6355-56, 31 August 1953 judicial officer not a decrease in his salary, after the SC has already decided that it was: defining
and interpreting the law is a judicial function
Nitafan v. CIR, G.R. No. 78780, 23 July 1987
Intent of the framers-1987 consti framers intended for the salaries of judiciary to be taxable

*People v. Macarandang, G.R. No. 12088, 23 December 1959 Peace officers exempted from issuance of license of firearms -included a secret
agent hired by a governor
People v. Mapa, G.R. No. L-22301, 30 August 1967 Abandoned macarandang ruling, the law is clear as to who are exempted, secret agents are not counted

People v. Jabinal, G.R. No. L-30061, 27 February 1974 Jabinal was arraigned while the Macarandang doctrine was in place, but decision was promulgated
under Mapa doctrine. Jabinal was acquited under stare decisis and retroactivity doctrine; lex
prospicit non respicit-the law looks forward not backward, applies to judicial decisions

SWS v. COMELEC, G.R. No. 208062, 27 April 2015 Govt regulation (police power) is justified if 1) subst. Govt interest, 2) narrowly tailored means

People v. Nazario, G.R. No. L-44143, 31 August 1988 Meaning of term

Unius est exclusio
alterius- where a statute
by its terms is expressly
limited to certain matters,
it may not, by
interpretation or
construction, be extended
to other matters-No
ordinance authorizing
mayor to issue permit for
cockfighting
dictated by context-
Canet v. Decena, G.R. No. 155344, 20 January 2004 owner (of fishpond) - KMU v. NEDA, G.R. 167798
does not include govt
as the ancient
III. Aids to Construction principle is that govt
is immune from
taxes. A vague
statute is one that
lacks comprehensible
standards that men of
common intelligence
must necessarily
guess at its meaning
and differ as to its
application

when the text itself of a
statute or a treaty is clear and
unambiguous, there is neither
necessity nor propriety in
resorting to the preamble or
headings or epigraphs of a
section for the interpretation
of the text
The best method of
interpretation is that which
makes laws consistent with
other laws. Changes made by
the legislature in the form of
amendments should be given
effect together with other
parts of the amended act
The title may indicate the legislative intent to extend or restrict the scope of the law and a
statute couched in a language of doubtful import will be construed to conform to the
Central Capiz v. Ramirez, G.R. No. L-16197, 12 March 1920 legislative intent as disclosed in its title.
Preamble as aid in statcon-Carrying of bladed weapon as in relation to
People v. Purisima, G.R. No. L-42050-66, 20 November 1978 subversion, rebellion, etc, yes, necessary element of the crime
Aboitiz Shipping Corporation v. Cebu, G.R. No. L-14526, 31 March 1965 whole context of the statute and not from an isolated part or particular
provision.
US v. Hart, G.R. No. L-8848, 21 November 1913 intended by the Legislature should be the relevant determinant of the interpretation
An argument based upon punctuation alone is not conclusive and the effect
People v. Yabut, G.R. No. 39085, 27 September 1933 of the la
Lingual text- weight depends on the language in which the statute was promulgated;
People v. Abilong, G.R. No. L-1960, 26 November 1948 “sufriendo privacion de libertad”
Matabuena v. Cervantes, G.R. No. 28771, 31 March 1971 Spirit of the law- if married couples are not allowed to donate inter vivos, why should
common law spouses be? Remedy the omission thru adherence to objective
Song Kiat Chocolate Factory v. Central Bank of the Philippines, G.R. No. L-8888, 29 November 1957 Courts are not bound by one
legislator’s opinion,
expressio unius est exclusion alterius wrongly applied, justice of
People v. Manantan, G.R. No. 14129, 31 July 1962 peace just added to general term judges based on intent of new law expressed in congressional
debates, concerning the
Akbayan v. COMELEC, G.R. No. 147066, 26 March 2001 application of existing laws;
only chocolate is exempted
Buenaseda v. Flavier, G.R. No. 106719, 21 September 1993 Noscitur-suspension as a punitive measure not a penalty from tax
Marcos v. Manglapus, G.R. No. 88211, 15 September 1989 - Dissenting
Weight accorded to contemporaneous
Philippine Sugar Central Agency v. Collector of Customs, G.R. No. L-27761, 6 December 1927 construction- the language of the act
could have been more specific, but
Lazatin v. Disierto, G.R. No. 147097, 5 June 2009 Stare decisis et non quieta movere-to adhere to precedents
and not unsettle things which are established): enjoins given its history and long continuous
Ient v. Tullet, G.R. No. 189158, 11 January 2017 adherence to judicial precedents=abandonment of ruling must construction, and what’s been
accomplished under it, govt is entitled
be based only on strong and compelling reasons-Acop vs
Office of the Ombudsman to receive money in question-best
interpretation of the law is usage
IV. Adherence to or Departure from, Language of Statute
National Federation of Labor v. NLRC, G.R. No. 127718, 2 March 2000
Pascual v. Pascual-Bautista, G.R. No. 84240, 25 March 1992
Solid Homes, Inc. v. Tan, G.R. No. 145156-57, 29 July 2005
US v. Toribio, G.R. No. L-5060, 26 January 1910
People v. Almueta, G.R. No. L-26551, 27 February 1976
Amatan v. Aujero, A.M. No. RTJ-93-956, 27 September 1995
Salvacion v. Central Bank, G.R. No. 94723, 21 August 1997
Gatchalian v. COMELEC, G.R. No. L-32560-61, 22 October 1970
Republic v. Register of Deeds of Roxas City, G.R. No. 158230, 16 July 2008
V. Interpretation of Words and Phrases
Kuenzle & Streiff v. Collector of Customs, G.R. No. 10710, 11 December 1915
Mustang Lumber, Inc. v. Court of Appeals, G.R. No. 104998, 18 June 1996
Llamado v. Court of Appeals, G.R. No. 84850, 29 June 1990
Colgate Palmolive v. Gimenez, G.R. No. L-14787, 28 January 1961
Ramirez v. Court of Appeals, G.R. No. 93833, 28 September 1995
People v. Flores, G.R. No. 188315, 25 August 2010
Vera v. Cuevas, G.R. No. L-33693-94, 31 May 1979
Garcia v. Social Security Commission, G.R. No. 170735, 17 December 2000
Chavez v. Judicial and Bar Council, G.R. No. 202242, 16 April 2013
City of Manila v. Laguio, G.R. No. 118127, 12 April 2005
VI. Statutes Construed as a Whole, and in Relation to other Statutes
Sajonas v. Court of Appeals, G.R. No. 102377, 5 July 1996
Tan Co v. Civil Register of Manila, G.R. No. 138496, 23 February 2004
Bloomberry Resorts and Hotels, Inc. v. BIR, G.R. No. 212530, 10 August 2016
Vinzons-Chato v. Fortune Tabacco Corporation, G.R. No. 141309, 19 June 2007
VII. Strict or Liberal Interpretation
Intestate Estate Vda. De Carugcong v. People, G.R. No. 181409, 11 February 2010
City of Manila v. Chinese Community of Manila, G.R. No. L-14355, 31 October 1919
Republic v. Ong, G.R. No. 175430, 18 June 2012

CIR v. Court of Appeals, G.R. No. 115349, 18 April 1997

Mobil Philippines Exploration, Inc. v. Customs Arrastre Service, G.R. No. L-23139, 17 December 1966

Azuela v. Court of Appeals, G.R. No. 122880, 12 April 2006

Ortigas & Co. v. Feati Bank and Trust Co., G.R. No. L-24670, 14 December 1979
Magtajas v. Pryce Properties Corporation Inc. G.R. No. 111097, 20 July 1994

In the matter of the adoption of Stephanie Nathy Astorga Garcia, G.R. No. 148311, 31 March 2005
Ortiz v. COMELEC, G.R. No. 78957, 28 June 1998
Enriquez v. Enriquez, G.R. No. 139303, 25 August 2005

VIII. Mandatory and Directory Statutes

Adasa v. Abalos, G.R. No. 168617, 19 February 2007

Grande v. Antonio, G.R. No. 206248, 18 February 2014

Guerrero v. RTC of Ilocos Norte, G.R. No. 109068, 10 January 1994

Gachon v. De Vera, G.R. No. 116695, 20 June 1997
Tatad v. Sandiganbayan, G.R. No. 72335-39, 21 March 1988

IX. Prospective and Retroactive Statutes

Morales v. Binay, G.R. No. 217126-27, 10 November 2015

Nasi-Villar v. People, G.R. No. 176169, 14 November 2008
People v. Ferrer, G.R. No. 32613-4, 27 December 1972

People v. Patalin, G.R. No. 125539, 27 July 1999

Pangcatan v. Manghuyop, G.R. No. 194412, 16 November 2016
Okabe v. Gutierrez, G.R. No. 150185, 27 May 2004

X. Amendment, Revision, Codification and Repeal

Estrada v. Caseda, G.R. No. L-1560, 25 October 1949

Mecano v. COA, G.R. No. 103982, 11 December 1992
People v. Pimentel, G.R. No. 100210, 1 April 1998

XI. Constitutional Construction

Manila Prince Hotel v. GSIS, G.R. No. 122156, 3 February 1997

David v. Senate Electoral Tribunal, 20 September 2016

Civil Liberties Union v. Executive Secretary, G.R. No. 83896, 22 February 1991
IBP v. Zamora, G.R. No. 141284, 15 August 2000
Nitafan v. CIR, G.R. No. 78780, 23 July 1987

Accord v. Zamora, G.R. No. 144256, 8 June 2005

Tondo Medical Center Employees Association, v. Court of Appeals, G.R. No. 167324, 17 July 2007
Pamatong, Esquire v. COMELEC, G.R. No. 161872, 13 April 2004