STATUTORY CONSTRUCTION

LESSON 1

COMPILATION OF PERTINENT CASES

CASE NO. 11

[GR No. L-15138, Jul 31, 1961]

BILL MILLER v. ATANACIO A. MARDO

112 Phil. 792

BARRERA, J.:

Facts:

Manuel Gonzales filed a complaint against Bill Miller, the owner and manager of Miller Motors, claiming
to be a driver of Miller from December 1, 1956, to October 31, 1957, when he was allegedly arbitrarily
dismissed without being paid separation pay. Gonzales filed this complaint with Regional Office No. 3 of
the Department of Labor. In response, Miller filed a petition with the Court of First Instance of Baguio
(Civil Case No. 759) to prohibit the Department of Labor's Hearing Officer from proceeding with the case,
arguing that the Hearing Officer lacked jurisdiction. The court issued a writ of preliminary injunction.

Issue:

Whether or not Reorganization Plan No. 20-A, which gave Regional Offices of the Department of Labor
the authority to adjudicate claims involving laborers' wages, overtime, separation pay, and similar issues,
contravened the Constitution and relevant laws by delegating quasi-judicial powers to administrative
entities.

Ruling:

The court ruled that Reorganization Plan No. 20-A, insofar as it conferred judicial power to the Regional
Offices over cases other than those falling under the Workmen's Compensation Law, was invalid and of
no effect. The court held that while administrative bodies could exercise quasi-judicial powers as
incidental to the performance of administrative functions, the delegation of jurisdiction over matters
exclusively vested in the courts was not permissible. Additionally, the court emphasized that the
procedure outlined in Section 6(a) of the Reorganization Act, which allowed for approval through
legislative inaction, was contrary to the constitutional requirements of positive and separate action by
each House of Congress.
 STATUTORY CONSTRUCTION

LESSON 1

COMPILATION OF PERTINENT CASES

CASE NO. 12

[GR No. 127255, 1997-08-14]

JOKER P. ARROYO v. JOSE DE VENECIA

277 SCRA 268

MENDOZA, J.:

Facts:

In the case of Joker P. Arroyo v. Jose de Venecia, the petitioners challenged the validity of Republic Act
No. 8240 (Sin Tax Law) which provides the excise tax structure for cigarettes and liquor, alleging that it
was passed in violation of the rules of the House of Representatives and, thus, unconstitutional. They
claimed that certain House rules were "constitutionally mandated" and that their violation amounted to
a violation of the Constitution itself. The bill in question was signed into law on November 22, 1996.

Issue:

Whether or not Republic Act No. 8240 was validly enacted, considering allegations of irregularities in the
legislative process that potentially violated House rules and the Constitution.

Ruling:

The Supreme Court ruled that the enrolled bill doctrine applied in this case. This doctrine holds that
when a bill has been signed by the presiding officers of both Houses of Congress and certified as duly
passed, the Court should accept it as law, barring clear evidence to the contrary. The Court noted that
the enrolled bill doctrine is based on the respect due to coequal and independent branches of
government and serves to avoid judicial interference in legislative processes. In this case, there was no
substantial evidence to challenge the due enactment of the law, and the Court upheld its validity. The
petition for certiorari and prohibition was dismissed.

Doctrine:

The enrolled bill doctrine, which presumes that a bill has been duly enacted when signed by the
presiding officers and certified by the secretaries of both Houses of Congress, unless clear evidence
suggests otherwise, was the central doctrine applied in this case.
 STATUTORY CONSTRUCTION

LESSON 1

COMPILATION OF PERTINENT CASES

CASE NO. 13

[GR No. 105371, 1993-11-11]

THE PHILIPPINE JUDGES ASSOCIATION v. HON. PETE PRADO

Facts:

The case revolves around the issue of the independence of the Judiciary in the Philippines. The
petitioners, who are judges from lower courts, challenged Section 35 of Republic Act No. 7354 (R.A. No.
7354) and its implementation through Circular No. 92-28 by the Philippine Postal Corporation. These
measures withdrew the franking privilege (free mailing of official documents) from various government
offices, including the Supreme Court, Court of Appeals, Regional Trial Courts, Metropolitan Trial Courts,
Municipal Trial Courts, Land Registration Commission, and Registers of Deeds. The petitioners argued
that these actions would prejudice their functions as judges.

Issue:

Whether or not the withdrawal of the franking privilege from the Judiciary, as stipulated in Section 35 of
Republic Act No. 7354, violates the constitutional requirement that every bill's title must express only
one subject.

Ruling:

The Court addressed the objection based on Article VI, Section 26(1) of the Constitution, which requires
every bill passed by Congress to embrace only one subject expressed in its title. The petitioners argued
that the withdrawal of the franking privilege from the Judiciary was not expressed in the title of R.A. No.
7354 and did not reflect its purposes. The Court disagreed with this contention and ruled that the title of
the law did not violate the Constitution. It clarified that the title of a bill is not required to cover every
detail of the measure but should fairly indicate the general subject and reasonably cover all provisions of
the act without misleading the legislature or the people. Requiring every detail to be in the title would
render legislation impossible. The Court found that the withdrawal of the franking privilege from certain
agencies was related to the principal objective of R.A. No. 7354, which was to create a more efficient
postal service system. Therefore, Section 35, as a repealing clause, did not need to be expressly included
in the title of the law.
 STATUTORY CONSTRUCTION

LESSON 1

COMPILATION OF PERTINENT CASES

CASE NO. 14

[GR No. L-23475 April 30, 1974]

HERMINIO ASTORGA (VICE MAYOR OF THE CITY OF MANILA), PETITIONER V. ANTONIO VILLEGAS (CITY
MAYOR OF MANILA), RESPONDENT

Facts:

In 1964, House Bill 9266 (HB 9266) was filed in the Philippines, which aimed to amend certain provisions
of the Revised Charter of the City of Manila. This bill was all about the powers and duties of the Vice
Mayor of Manila. The bill underwent legislative processes, including amendments in the Senate.
However, when the President signed the bill into law as RA 4065, a dispute arose regarding which version
of the bill had been approved by Congress. One senator claimed that his amendments, which were
crucial to the bill, were not included in the final version signed into law. This led to a legal challenge.

Issue:

Whether or not the enrolled bill, as signed by the President, should be considered the valid and effective
version of the law, or if the journal entries of the legislative proceedings, which showed that certain
amendments were made but not reflected in the enrolled bill, should be the decisive factor?

Ruling:

The Supreme Court ruled that the journal entries of the legislative proceedings, which revealed that
substantial amendments were made but not included in the enrolled bill signed by the President, should
be considered the decisive factor in determining the validity of the law. This means that the enrolled bill,
as signed by the President, was not the valid and effective version of the law. The Court emphasized that
approval by Congress, rather than the signatures of the presiding officers, is essential for a bill to become
law. Therefore, the law in question was not duly enacted, and the Court upheld the journal entries as the
accurate record of the law's passage.
 STATUTORY CONSTRUCTION

LESSON 1

COMPILATION OF PERTINENT CASES

CASE NO. 15

CONTINENTAL OIL CO. V. CITY OF SANTA FE

36 N.M. 343, 15 P.2D 667 (N.M. 1932)

Facts:

In Continental Oil Co. v. City of Santa Fe, the City of Santa Fe sought to impose a license fee on the
storage of gasoline within the city. Continental Oil Company, a gasoline distributor, challenged this fee,
arguing that it was unconstitutional and violated the commerce clause of the United States Constitution.

Issue:

Whether or not the City of Santa Fe had the authority to impose a license fee on the storage of gasoline
and whether this fee violated the commerce clause of the U.S. Constitution was the central issue in this
case.

Ruling:

The court upheld the authority of the City of Santa Fe to impose the license fee on gasoline storage. It
found that the fee was not a tax but rather a regulatory measure designed to ensure safety and prevent
fire hazards. Therefore, it did not violate the commerce clause, as it was not an undue burden on
interstate commerce.

Doctrine:

The court relied on the distinction between taxes and regulatory fees, noting that regulatory fees
imposed for legitimate regulatory purposes, such as public safety, do not necessarily violate the
commerce clause. In this case, the fee was deemed a reasonable regulation rather than an
unconstitutional burden on commerce.