STATUTORY CONSTRUCTION

Peter Leo M. Ralla

Statutory Construction
Cases: (Read and digest)

Read the law and cases, thereafter digest:

1) Arts. 1 to 18 (R.A. No. 386, Civil Code);

2) Article VIII, Sec. 1, 1987 Constitution;
3) Endencia v. David, G.R. No. L-6355-56, August 31, 1953;
4) Francisco, Jr. v. House of Representatives, G.R. Nos. 160261, 160362,
160263, 160277, 160292, 160295, 160310, 160318, 160342, 160343,
160360, 160365, 160370, 160376, 160392, 160397, 160403 & 160405,
November 10, 2003;
5) People v. Sereno, G.R. No. 237428, June 19, 2018.
6) Nestle Philippines, Inc., v. Court of Appeals, G.R. No. 86738, November 13,
1991.
7) Barrameda v. Moir, G.R. No. 7927, August 8, 1913;
8) The Government of the Philippine Islands v. Springer, G.R. No. 26979, April 1,
1927;
9) People v. Concepcion, G.R. No. 19192A, February 28, 1923; modify the
period of imprisonment imposed by the trial judge by adding one day
thereto, thus placing the penalty within the maximum of the maximum
degree of prision correccional
10) De Jesus v. City of Manila, G.R. No. 9337, December 24, 1914; W/N
Petitioner should still pay the taxes which were not assessed before -
Petitioner should only pay the taxes when he was the owner of the
property
11) Sy Kiong v. Sarmiento, G.R. No. L-2934, November 29, 1959; W/N the sales
of flour made by the Petitioner to bakeries to be manufactured into bread
are retail or wholesale - The sale of flour to bakeries to be manufactured
into bread and to be resold to the public, in the absence of any express
provision of law on the matter, should be treated as a sale at retail and
should subject the vendor to the retail tax law.
12) Baron v. EPE Transport, Inc., G.R. No. 202645, August 5, 2015. - okay
13) Prasnik v. Republic, G.R. No. L-8639, March 3, 1956 W/N the Civil Code
allows for the adoption of acknowledged natural children of the father or
mother. - The law intends to allow adoption whether the child be
recognized or not. If the intention were to allow adoption only to
unrecognized children, Article 338 would be of no useful purpose.
The rights of an acknowledged natural child are much less than those of a
legitimated child. Contending that this is unnecessary would deny the
illegitimate children the chance to acquire these rights. The trend when it
comes to adoption of children tends to go toward the liberal. The law does
not prohibit the adoption of an acknowledged natural child which when
compared to a natural child is equitable. An acknowledged natural child is
a natural child also and following the words of the law, they should be
allowed adoption.
14) Commissioner of Customs v. ESSO Standard Eastern, Inc., G.R. L-28329,
August 7, 1975; okay
15) Commissioner of Internal Revenue v. Philippine Airlines, Inc., G.R. No.
180043, July 14, 2009 - okay
 16) Legaspi v. Executive Secretary, L-36153, November 28, 1975 W/N
Petitioner is entitled to both gratuity benefits under C.A. No. 186, as
amended by RA 1616, and RA 3844, as amended by RA 6389. HELD: No.
There is nothing in RA 3844, as amended by RA 6389, that would suggest
that an employee who is laid-off or prefers to be laid-off can receive two
pension benefits, one under its provisions and another pursuant to C.A. No.
186. This interpretation is more in line with the policy of the law embodied
in C.A. No. 186 prohibiting an employer from paying double retirement
benefits to an employee. Being the law governing the retirement of
government employees, all other laws extending retirement benefits to
government employees should, in case of ambiguity, be construed in
relation to C.A. No. 186 and in the light of its provisions. It is a rule of
statutory construction that when the legislature enacts a provision, it is
understood that it is aware of previous statutes relating to the same
subject matter, and that in the absence of an express repeal or
amendment therein, the new provision should be deemed enacted
pursuant to the legislative policy embodied in prior statutes, which should
all be construed together.
17) Manila Lodge No. 761 v. Court of Appeals, G.R. No. L-41001, September 30,
1976 W/N the subject property was patrimonial property of the City of Manila.
HELD: The petitions were denied for lack of merit. The court found it necessary to
analyze all the provisions of Act No. 1360, as amended, in order to unravel the
legislative intent. The grant made by Act No. 1360 of the reclaimed land to the
City of Manila is a grant of a “public” nature. Such grants have always been
strictly construed against the grantee because it is a gratuitous donation of public
money or resources, which resulted in an unfair advantage to the grantee. In the
case at bar, the area reclaimed would be filled at the expense of the Insular
Government and without cost to the City of Manila. Hence, the letter of the
statute should be narrowed to exclude matters which, if included, would defeat
the policy of legislation.
18) Ildefonso v. Sibal, G.R. No. L-12181, September 30, 1959; - okay
19) Reyes v. De la Cruz, G.R. No. L-12729, March 30, 1959. - okay
20) Power Generation Employees Association-NPC v. National Power Corporation,
G.R. No. 187420, August 9, 2017. - okay