Baga v. Philippine National Bank, G.R. No. 9695, September 10, 1956.

Doctrine; ​Where there is ambiguity in a statute or where a statute is susceptible to

more than one interpretation, courts may resort to the explanatory note to clarify its
ambiguity and ascertain the purpose or intent of the statute. The statute may then be
so construed as to give effect to the purpose or intent disclosed in its explanatory
note.

Facts; Petitioner was the recipient of benefits with Respondent as the guardian under RA
390 or the Uniform Veterans Guardianship Act which was passed with the intention of being
modelled after the US version. RA 390 provides that guardianship can only be terminated
upon reaching the age of majority. Petitioner alleges that she has married and has become
emancipated under Art. 399 of the New Civil Code thus terminating the guardianship.

Issue: Whether or not Art. 399 of the Civil Code shall prevail over RA 390.

Ruling:No. The Civil Code does not prevail. It was the clear intent of the legislator to create
a uniform law for material aid. Inserting provisions of the Civil Code would result in
discordance with intent. RA 390 is a special law and thus must be taken to constitute an
exception to the general law which is the Civil Code. RA 390 Sec. 23 applies
notwithstanding any other provisions of law relating to judicial restoration and discharge of
guardians.

Where there is ambiguity in a statute or where a statute is susceptible to more than

one interpretation, courts may resort to the explanatory note to clarify its ambiguity
and ascertain the purpose or intent of the statute. The statute may then be so
construed as to give effect to the purpose or intent disclosed in its explanatory note.

Article 399. Emancipation by marriage or by voluntary concession shall terminate parental

authority over the child's person. It shall enable the minor to administer his property as
though he were of age, but he cannot borrow money or alienate or encumber real property
without the consent of his father or mother, or guardian. He can sue and be sued in court
only with the assistance of his father, mother or guardian. (317a)

REPUBLIC ACT NO. 390 - AN ACT CONCERNING THE GUARDIANSHIP OF

INCOMPETENT VETERANS, OTHER INCOMPETENTS AND MINOR BENEFICIARIES
OF THE VETERANS ADMINISTRATION