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Chapter 3 Statcon Case Digests PDF
Chapter 3 Statcon Case Digests PDF
Facts:
Roy Degamo succeeded in having carnal knowledge with Ellen Virtudazo against her
will. As a result of the rape, Ellen became temporarily insane until the pendency of the case. Dr.
Go attested the insanity of the victim. Hence, Degamo was charged and found guilty with the
crime of rape qualified by the circumstance of insanity. Degamo argues that Ellen had not
become insane by reason of rape because she gave intelligent answers on the witness stand.
Issue:
Whether or not the Degamo’s crime of rape should be qualified by temporary insanity.
Ruling:
There is no doubt that the highest penalty shall be imposed if the victim if the victim
becomes permanently insane, there is no ruling yet whether temporary insanity still falls within
the purview of provision. It is a hornbook doctrine in statutory construction that it is the duty of
the court in construing a law to determine the legislative intention from its language. An
examination of the deliberation of the lawmakers in enacting R.A. No. 2632, convinces us that
the degree of insanity, whether permanent or temporary, is not relevant in considering the same
as a qualifying circumstance for as long as the victim has become insane by reason or on
occasion of the rape.
Abaquin Security vs Hon. Diego Atienza G.R. No. 72971 October 15, 1990
Facts:
Petitioner, Abaquin Security (Abaquin), employed Antonio Jose as a security guard. Due
to his failing health and to withdraw his cash deposits with Abaquin, Jose voluntarily resigned.
Relying on the absence of any management policy or any collective bargaining agreement,
Abaquin paid Jose only his cash deposits. Jose filed with the Labor Arbiter a complaint against
Abaquin for separation pay and retirement benefits. The Arbiter dismissed the complaint on the
grounds that the retirement benefits under Rule 1, Book IV of the rules and regulations
implementing the labor code is subject to tha existence of a collective bargaining agreement or
management policy and Jose cannot claim benefits which are not granted by the Labor Code,
otherwise the Ministry of Labor would be guilty of Legislative usurpation. On appeal, the NLRC
reversed the decision of the arbiter. The NLRC construed Section 14 (a) of Rule I, Book VI of
the Implementing Rules and Regulations of the Labor Code in relation to the second paragraph
of Article 288 as entitling a retiring employee to termination pay of one-half (½) month for every
year of service in the absence of any agreement or employer policy on retirement pay. It ruled
that said Section 14 (a) was intended "to give full effect and application to Article 288 of the
Labor Code which covers all retiring employees, regardless of the existence of any agreement,
company policy or otherwise.”
Issue:
Whether or not Jose should be given retirement benefits under the implementing rules
Ruling:
While it is true that the contemporaneous construction placed upon a statute by executive
officers whose duty is to enforce it should be given great weight by the courts, still if such
construction is so erroneous, as in the instant case, the same must be declared as null and void. It
is the role of the Judiciary to refine and, when necessary, correct constitutional interpretation.
The interpretation given in the case by the NLRC to Section 14 (a) of the implementing rule is in
harmony with Article 288.
US vs Hart G.R. No. L-8327 March 28, 1913
Facts:
Hart was caught in a gambling house and was penalized under Act No. 519 which
punishes “every person found loitering about saloons or dram shops or gambling houses, or
tramping or straying through the country without visible means of support”. The said portion of
the law is divided into two parts, separated by the comma, separating those caught in gambling
houses and those straying through the country without means of support. Though it was proven
that Hart and the other Defendants had “visible means of support”, it was under the first part of
the portion of law for which they were charged with. The prosecution persisted that the phrase
“without visible means of support” was in connection to the second part of the said portion of
Act No. 519, therefore was not a viable defense.
Issue:
Whether or not Hart should be charged with vagrancy
Ruling:
The construction of a statute should be based upon something more substantial than mere
punctuation. If the punctuation gives it a meaning which is reasonable and is in apparent accord
with legislative will, it may be as an additional argument for adopting the literal meaning of the
words in the statute as thus punctuated. An argument based on punctuations alone is not
conclusive and the court will not hesitate to change the punctuation when necessary to give the
act the effect intended by the legislature, disregarding superfluous and incorrect punctuation
marks, or inserting others when necessary. In as much as defendant had, “visible means of
support” and that the absence of such was necessary for the conviction for gambling
and loitering in saloons and gambling houses, defendants are acquitted
People of the Philippines vs. Purisima G.R. No. L-42050-66 November 20, 1978
Facts:
26 petitions for review filed are consolidated in a decision involving a basic question of
law. Information were filed charging the respective accused with “Illegal possession of deadly
weapon” in violation of Presidential Decree Number 9. An order quashing or dismissing the
information, on a common ground that the information did not allege facts which constitute the
offense penalized by Presidential Decree number 9 because it failed to state one essential
element of the crime.
Issue:
Whether or not, PD no.9 (3) shows that the prohibited acts need not be related to
subversive activities and the act prescribed is essentially an offense (malum prohibitum)
penalized for reasons of public policy.
Ruling:
The petitions for review were denied. PD no.9 (3) provides and condemns not only the
carrying of said weapon in connection with the commission of the crime. In statutory offenses,
the intention of the accused is immaterial. When ambiguity exists, it becomes a judicial task to
construe and interpret the true meaning and scope of the measure. The two elements of the
offense covered by this PD no.9 (3) must be alleged in the information in order that the latter
may constitute a sufficiently valid charge.
Philippine Sugar Centrals Agency vs. Insular Collector of Customs G.R. No. L-2776
December 6, 1927
Facts:
The Philippine Sugar Centrals Agency at all times, acted as a representative of the Ma-ao
Sugar Central Company. The plaintiff shipped 5,124,416 gross kilograms of centrifugal sugar
consigned to the United States that the said sugar was laden through a wharf built, owned and
maintained solely by Ma-ao Sugar Central Company, leased to it by the Government of
Philippine Islands. Insular Collector of Customs assessed and collected wharfage dues on sugar
at 2 pesos per thousand gross kilograms with a total amount of 10,248.84 pesos. The plaintiff
paid, under protest, the said amount but overruled by the Insular Collector of Customs.
Issue:
Whether or not, the Government of Philippine Islands can legally collect the duty of 1
dollar per gross ton of 1,000 kilograms as a charged for wharfage.
Ruling:
August 5, 1909, the Congress of the United States passed what is known as the
"Philippine Tariff Act of 1909," entitled "An Act to raise revenue for the Philippine Islands, and
for other purposes," section 14 of which, under the head of "Wharfage," states that there shall be
levied and collected upon all articles, goods, wares, or merchandise, except coal, timber and
cement, the product of the Philippine Islands, exported through ports of entry of the Philippine
Islands, or shipped therefrom to the United States or any of its possessions, a duty of one dollar
per gross ton of one thousand kilos, as a charge for wharfage, whatever be the port of destination
or nationality of the exporting vessel: Provided, that articles, goods, wares, or merchandise
imported, exported, or shipped in transit for the use of the Government of the United States, or of
that of that of the Philippine Islands, shall be exempted from the charges prescribed in this
section. The Government of Philippine Islands can legally collect the duty of 1 dollar per gross
ton of 1,000 kilograms as a charged for wharfage.