CERTIFICATION

I do hereby certify that this

Case Digest is entirely my work,
reflecting my understanding of
the statutory construction
principles covered in this
course.

ANDREA B. OBERIO

CASE DIGEST REPORT

ATTY. CHARITO F. RODRIGUEZ
Table of Contents
Casco Philippine Chemical Co., Inc. vs Gimenez..................................................4
Astorga vs Villegas.................................................................................................5
Flores vs. Commission on Elections.......................................................................6
Libanan vs HRET...................................................................................................7
People vs Jabinal y Carmen....................................................................................8
Philippine International Trading Corporation (PITC) vs COA..............................9
People vs Eschavez, Jr..........................................................................................10
U.S. vs Hart...........................................................................................................11
Central Bank Employees Association, Inc. vs BSP..............................................12
People vs Mangulabnan........................................................................................13
People vs Manantan..............................................................................................14
Artates vs Urbi......................................................................................................15
Aznar vs Yapdianco..............................................................................................16
People vs Degamo................................................................................................17
National Federation of Labor vs National Labor Relations Commission............18
King vs Hernaez....................................................................................................19
Comendador vs De Villa.......................................................................................20
Amatan vs Aujero.................................................................................................21
Ursua vs CA..........................................................................................................22
Co Kim Cham vs Tan Keh....................................................................................23
Salvacion vs Central bank of the Philippines.......................................................24
Felife, Sr. vs Leuterio...........................................................................................25
Matabuena vs Cervantes.......................................................................................26
Romualdez vs Sandiganbayan..............................................................................27
People vs Santiago................................................................................................28
Ramirez vs CA......................................................................................................29
Pilar vs. COMELEC.............................................................................................30
Carandang vs Santiago..........................................................................................31
Vera vs Cuevas.....................................................................................................32
Mutuc vs COMELEC...........................................................................................33
E.B. Villarosa & Partner Co., Ltd. Vs Benito.......................................................34
Cagayan Valley Enterprises, Inc. vs CA...............................................................35
U.S. vs Santo Nino................................................................................................36

1
 Office of Ombudsman vs Masing.........................................................................37
Lopez vs CA.........................................................................................................38
Ang Bagong Bayani vs COMELEC.....................................................................39
Republic Flour Mills vs Comm. Of Customs.......................................................40
Canet vs Decena....................................................................................................41
City of Baguio vs Marcos.....................................................................................42
People vs Rivera...................................................................................................43
Aboitiz Shipping vs City of Cebu.........................................................................44
Agcaoili vs Suguitan.............................................................................................45
Feliciano vs Aquino..............................................................................................46
People vs Subido...................................................................................................47
In Re State of Jonhson..........................................................................................48
Unabia vs City Mayor...........................................................................................49
Traders Insurance vs Golangco.............................................................................50
Manila Lodge No. 761 vs CA...............................................................................51
Automotive Parts vs Lingad.................................................................................52
Nilo vs CA............................................................................................................53
Escribano vs Avila................................................................................................54
Litex Employees Association vs Eduvala.............................................................55
Regalado vs Yulo..................................................................................................56
Central Azucarera vs. CA.....................................................................................57
Ramirez vs CA......................................................................................................58
Celestial Nickle Mining vs Microasia..................................................................59
Basiana vs Luna....................................................................................................60
Arenas vs City of San Carlos................................................................................61
Escalante vs Santos...............................................................................................62
Salaysay vs. Castro...............................................................................................63
Commission of Customs vs CTS..........................................................................64
Gloria vs CA.........................................................................................................65
Buenaseda vs Flavier............................................................................................66
Munoz Co vs Hord................................................................................................67
Greenfield vs Meer...............................................................................................68
Carolina Industries vs CMS Stocks......................................................................69
Republic vs Meralco.............................................................................................70
San Miquel Corporation vs Inciong......................................................................71

2
 Maceda vs Macaraeg............................................................................................72
Vera vs Cuenca.....................................................................................................73
Nestle Philippines vs CA......................................................................................74
Phil Sugar Central vs Collector of Customs.........................................................75
Manila Jockey Club vs Games and Amusement..................................................76
Alexander Howden vs CIR...................................................................................77
CIR vs American Express.....................................................................................78
Assoc. Sugar vs Corn of Customs........................................................................79
Tung Chin Hui vs Rodriguez................................................................................80

3
Casco Philippine Chemical Co., Inc. vs Gimenez
GR No. L-17931
Facts
Casco Philippine Chemical Co., Inc. is contesting the Auditor General's denial of their
refund claim associated with the Foreign Exchange Margin Fee Law. Under Republic
Act No. 2609, the Central Bank implemented Circular No. 95, imposing a uniform
25% margin fee on foreign exchange transactions. Casco, engaged in manufacturing
synthetic resin glues, purchased foreign exchange for importing urea and
formaldehyde, crucial raw materials, in November and December 1959, incurring a
margin fee of P33,765.42. Another purchase in May 1960 resulted in a margin fee of
P6,345.72. Despite seeking a refund based on a Monetary Board resolution exempting
separate importations of urea and formaldehyde, the Auditor of the Central Bank
rejected the vouchers, a decision affirmed by the Auditor General. The petitioner
contends that the term "urea formaldehyde" in Section 2, paragraph XVIII of
Republic Act No. 2609 should be construed as “urea and formaldehyde” and that
herein respondents have erred in holding otherwise.
Issue
W/N the urea and formaldehyde are exempt by the law from the payment of margin
fee in view that the bill approved contained copulative conjunction “and” between the
term “urea” and “formaldehyde”.
Held
No. The court ruled that "urea formaldehyde" should be considered a finished
product, distinct from the separate raw materials "urea" and "formaldehyde." The
National Institute of Science and Technology's definition supported this view. Despite
the petitioner's argument that the bill approved in Congress used the conjunction
"and" between "urea" and "formaldehyde," the court emphasized the conclusive
nature of the enrolled bill. Individual statements during the bill's consideration in the
Senate were deemed insufficient to reflect the collective intent of both houses of
Congress.
The court underscored the separation of powers, that if there were errors in the bill,
the remedy lies in legislative processes like amendment or curative legislation, not
judicial intervention. This reinforces the rule that the enrolled bill is conclusive in

4
determining the intent of the measure passed by Congress and approved by the
President.

Astorga vs Villegas
GR No. L-23475
Facts
In 1964, Manila Mayor Antonio Villegas disregarded Republic Act No. 4065 through
circulars, prompting then Vice-Mayor Herminio Astorga to file a petition before the
Supreme Court. Villegas contested the validity of RA 4065, claiming it was never
properly enacted due to an error in the version sent for approval. The House Bill
9266, defining the powers of the Vice-Mayor, had undergone amendments in the
Senate by Sen. Tolentino, but the version signed into law lacked these changes. As
such, the Senate President withdrew his signature in the enrolled bill. Thereafter, the
President of the Philippines also officially withdrew his signature on the bill.
Issue
W/N the legislative journal can be used to declare that the bill is not duly enacted in
the absence of attestation of evidence of the bill’s due enactment?
Held
Yes. The court held that the constitution requires that each House shall keep a journal
which in the absence of attestation of evidence of the bill’s due enactment, the court
may resort to the journals of the Congress to verify such. Journal’s content revealing
substantial amendments not reflected in the signed text, can be used to declare that the
bill was not duly enacted. The withdrawal of the signature of the President of the
Senate and the Chief Executive reinforces this view, indicating a rectification of the
error and a declaration that the intended bill was never made into law. Upholding the
unimpeachability of the legislative journals prevents the perpetuation of legislative
mistakes and ensures fidelity to the truth.

5
Flores vs. Commission on Elections
GR No. 89604
Facts
Petitioner Roque Flores was declared punong barangay according to Section 5 of R.A.
6679 after winning the March 1989 elections in Barangay Poblacion, Tayum, Abra.
However, a legal challenge by Rapisora, who finished second, led to the removal of
two stray votes, resulting in Rapisora being declared the winner. The Municipal
Circuit Trial Court and the RTC upheld this decision, emphasizing that votes for
"Flores" without a first or middle name should be considered invalid, reducing Roque
Flores to second place. The petitioner appealed to the COMELEC, but it was
dismissed based on Section 9 of R.A. 6679, stating that RTC decisions on factual
matters in barangay election protests are final and non-appealable.
Issue
W/N the decision of Municipal or Metropolitan Courts in barangay election contests
are subject to the exclusive appellate jurisdiction of the COMELEC considering
Section 9 of RA No. 6679
Held
Yes, The dismissal of the appeal is justified, but on an entirely different and more
significant ground, to wit, Article IX-C, Section 2(2) of the Constitution,
providing that the COMELEC shall “Exercise exclusive original jurisdiction over all
contests relating to the elections, returns, and qualifications of all elective regional,
provincial, and city officials, and appellate jurisdiction over all contests involving
elective municipal officials decided by trial courts of general jurisdiction, or involving
elective barangay officials decided by trial courts of limited jurisdiction”. Municipal
or Metropolitan Courts being courts of limited jurisdiction, their decisions in barangay
election contests are subject to the exclusive appellate jurisdiction of the COMELEC
under the afore-quoted section. Hence, the decision rendered by the Municipal Circuit
Trial Court should have been appealed directly to the COMELEC and not to the RTC.
Accordingly, Section 9 of RA No. 6679, insofar as it provides that the decision of the

6
municipal or metropolitan court in a barangay election case should be appealed to the
RTC, must be declared unconstitutional.

Libanan vs HRET
GR No. 129783
Facts
In the May 1995 elections for Eastern Samar's lone congressional seat, Jose Ramirez
was proclaimed the winner by the Provincial Board of Canvassers. Petitioner
Marcelino Libanan filed an election protest with the HRET, alleging electoral
irregularities instigated by Ramirez. During the revision of contested precincts,
Ramirez sought to withdraw his counter-protest in specific precincts. The focus of the
dispute revolves around alleged spurious ballots. The HRET ruled in favor of
Ramirez. Libanan, dissatisfied, requested reconsideration, arguing that the absence of
the BEI Chairman's signature on the ballots suggested they were not issued to voters
during the elections.
Issue
W/N ballots not signed at the back by the Chairman of the BEI are spurious since it
violated Section 24 of RA No. 7166
Held
No, the ballots were not spurious. According to Section 24 of R.A. No. 7166, the
absence of the BEI Chairman's signature at the back of the ballot, while constituting
an election offense, does not automatically render the ballot spurious. The law holds
the BEI Chairman accountable for such omissions without deeming the ballot invalid.
The court rejects the petitioner's suggestion to interpret the law strictly, highlighting
that the primary goal is to discern and uphold the voter's intention. Stricter
interpretation would unfairly invalidate ballots due to omissions by election officials,
compromising the constitutional right of suffrage. The ballots should not be deemed
spurious solely based on the absence of the BEI Chairman's signature.

7
People vs Jabinal y Carmen
GR No. L-30061
Facts
In 1974, an appeal was made challenging the judgment of the Municipal Court of
Batangas in Criminal Case No. 889, where the accused was found guilty of Illegal
Possession of Firearm and Ammunition. The case raised concerns about the
retroactive application of the Supreme Court's ruling in People v. Mapa. The accused,
despite having appointments as a Secret Agent and Confidential Agent, was convicted
for possessing a firearm without the required license. The trial court, acknowledging
the accused's appointments, held him criminally liable based on the reversal and
abandonment of prior Supreme Court decisions in People v. Macarandang and People
v. Lucero.
Issue
W/N the doctrine in People vs Mapa can be applied retroactively so as to convict the
accused.
Held
No. The court ruled that decisions of the Supreme Court serve as evidence of what
laws mean, incorporating judicial interpretations into the legal system. Stating the
legal maxim "legis interpretado legis vim obtinet," the court emphasized that its
interpretations carry the force of law. While recognizing that the prior doctrines in
Lucero and Macarandang were overruled by the Mapa case in 1967, the court
emphasizes that the new doctrine should apply prospectively and not retroactively.
The court held that the appellant, relying on the old doctrine when appointed as a
Secret Agent, should be absolved as criminal liability cannot be imposed retroactively
for an act deemed non-punishable at the time of its occurrence.

8
Philippine International Trading Corporation (PITC) vs COA
GR No. 205837
Facts
The PITC, created under Presidential Decree No. 252, initially enjoyed exemption
from the rules and regulations of the Office of the Compensation and Position
Classification (OCC). However, Executive Orders No. 756 and No. 877 authorized
PITC's reorganization and eventually brought it under the coverage of Republic Act
No. 6758, eliminating its previous exemption from OCC rules. In the case of
Philippine International Trading Corporation v. Commission on Audit, the Supreme
Court ruled that PITC is no longer exempt from OCC rules, emphasizing the intent of
the law to standardize compensation across government personnel. Despite the ruling,
PITC continued allocating funds for retirement benefits based on Executive Order No.
756. In seeking a prospective application of the Supreme Court decision, PITC argued
that the vested rights of qualified employees should be honored. The Commission on
Audit denied PITC's appeal and affirmed the disapproval of its Annual Audit Report
for 2010.
Issue
W/N the decision in GR No. 183517 should be applied prospectively from the time it
became final.
Held
No. The court ruled against the prospective application of its decision in G.R. No.
183517. It clarified that the decision did not reverse an old doctrine or establish a new
one but rather interpreted the meaning and application of Section 6 of Executive
Order No. 756. The court emphasized that prior to this decision, there was no other
ruling explaining the nature of retirement benefits under the said provision. The court
held that its interpretation retroacts to the date when Executive Order No. 756 was
enacted, aligning with the principle that judicial interpretation becomes part of the law
as of the original enactment date. On the other hand, the court invoked the principle

9
that a new doctrine should be applied prospectively and not to parties who relied in
good faith on the old doctrine, preserving the principles of fairness and justice.

People vs Eschavez, Jr.

GR No. L-47757-61
Facts
Petitioner Abundio R. Ello initiated legal action against 16 individuals for squatting,
as penalized by Presidential Decree No. 772. However, the case was dismissed by
respondent Judge Echaves based on two grounds. First, it was argued that the accused
allegedly entered the land through "stealth and strategy," while the decree specifies
entry with the use of force, intimidation, threat, or taking advantage of the absence or
tolerance of the owner. Second, the judge contended that, applying the rule of
ejusdem generis, the decree does not extend to the cultivation of a grazing land.
Issue
W/N PD No. 772 which penalizes squatting and similar acts, also apply to agricultural
land
Held
No. The lower court correctly ruled that the decree does not apply to pasture lands
because its preamble shows that it was intended to apply to squatting in urban
communities or more particularly to illegal constructions in squatter areas made by
well to do individuals. The squatting complained of involves pasture lands in rural
areas. The rule of ejusdem generis invokes by the trial court does not apply to this
case. Here, the intent of the decree is unmistakable. It is intended to apply only to
urban communities, particularly to illegal constructions. The rule of ejusem generis is
merely a tool of statutory construction which is resorted when the legislative intent is
uncertain.

10
U.S. vs Hart
GR No. 8848
Facts
Hart, Miller, and Natividad faced vagrancy charges under Act No. 519 and were
sentenced to imprisonment and fines. Hart, who operated two gambling games, had
recently pleaded guilty to a gambling charge before the vagrancy arrest. Despite
earning a living from lawful businesses, the prosecution relied on their participation in
gambling games, explicitly prohibited by Gambling Act No. 1757, as grounds for
vagrancy charges. The evidence for conviction centered on their presence in licensed
saloons engaged in unlawful activities. Section 1 of Act No. 519 outlined seven
clauses, specifying classes of persons considered as vagrants, including those found
loitering in saloons or gambling houses without visible means of support.
Issue
W/N the “without visible means of support” apply to “every person found loitering
about saloons or dram shops”
Held
Yes. If “without visible means of support” does not apply to “every person found
loitering about saloons of dram shops or gabling houses”, practically all who frequent
such places commit a crime of vagrancy. In terms of statutory construction, the ruling
emphasized the duty of the courts to ascertain the true legislative intention when
interpreting laws. It highlighted that the punctuation in a statute could be considered as
an additional argument for adopting the literal meaning of the words if it aligns with
legislative will. However, the court clarified that punctuation alone is not conclusive,
and they would not hesitate to adjust it when necessary to achieve the intended effect
of the law.

11
Central Bank Employees Association, Inc. vs BSP
GR No. 148208
Facts
The petitioner, Central Bank Employees Association, contends that the last proviso in
Section 15(c), Article II of R.A. No. 7653 creates an unconstitutional divide between
two classes of BSP employees: the exempt class comprising BSP officers and those
not covered by the Salary Standardization Law (SSL), and the non-exempt class,
consisting of rank-and-file personnel in Salary Grade 19 and below. The core
argument is that this classification is deemed "a classic case of class legislation,"
asserting that it lacks substantial distinctions based on real differences, relying solely
on the salary grade (SG) of the BSP personnel's positions. The petitioner further
claims that such a classification is not aligned with the main purpose of Section 15(c),
Article II of R.A. No. 7653, which, according to them, is primarily aimed at
establishing professionalism and excellence across all levels within the BSP.
Issue
W/N Section 15(c), Article II of R.A. No. 7653 runs afoul of the constitutional
mandate that "No person shall be denied the equal protection of the laws.”
Held
Yes. The disputed Section of RA No. 7653 violate the equal protection clause
provided by the Constitution. The guaranty of equal protection doesn't require
identical application of laws to all citizens but prohibits arbitrary discrimination.
Congress is granted leeway in classification, but such distinctions must be based on
substantial differences and be germane to the law's purpose, applying uniformly
within the same class. The court found that the second challenge to the
constitutionality of Section 15(c), Article II of Republic Act No. 7653 revolves
around Congress's irrational and inconsistent policy, leading to oppressive results for
BSP rank-and-file compared to other GFIs. The violation of equal protection is

12
heightened by the acknowledgment that if Congress had enacted a law solely
exempting the eight GFIs from the SSL, excluding BSP rank-and-file employees
would lack substantial basis. The court asserts that the legislative privilege to grant or
deny such exemptions is subject to judicial review, especially when distinctions are
superficial and lack substantial differences. The ruling underscores the court's duty to
correct arbitrariness, aligning with the true intent of the statute, which is to ensure fair
and just treatment within defined classes.

People vs Mangulabnan
GR No. L-8919
Facts
Report of gunfire woke the spouse and their minor children in their house late in the
evening. At the same time, someone broke the wall of the kitchen and entered the
room armed to loot the house. Vicente Pacson hid in the ceiling as the intruders
nabbed the items and shot upwards as a warning. After they were gone, Vicente was
found dead in the ceiling lying face downward
Issue
W/N the accused is guilty of Robbery with homicide under Article 294 Paragraph 1 of
the Revised Penal Code
Held
Yes. The accused is guilty of Robbery with homicide. Article 294, paragraph 1 of the
RPC provides, according to its English text, that the crime of robbery with homicide
“when by reason or on occasion of the robbery the crime shall have been committed.
But this is a poor translation of the Spanish text “Cuando con motive o con ocasion del
robo resultare homicide”. The Spanish text must prevail because the RPC was made
into law in its Spanish Text and given this, the crime committed is robbery with
homicide, even if the homicide supervened by mere accident.

13
People vs Manantan
GR No. L-14129
Facts
Manantan was charged with violating Section 54 of the Revised Election Code, which
prohibits certain officers from aiding any candidate or exerting influence in an
election. The lower court initially denied the motion to dismiss, holding that a justice
of the peace falls within the scope of Section 54. However, the defense cited a decision
in People v. Macaraeg, arguing that a justice of the peace is excluded from the
prohibition of Section 54. The lower court eventually dismissed the information based
on this argument. The crucial point of contention revolves around whether the term
"judge" in Section 54 includes a justice of the peace. Defendant Manantan argues that
the omission of "justice of the peace" in Section 54 signifies the legislative intention to
exclude them from its operation, referencing the historical context from Section 449 of
the Revised Administrative Code.
Issue
W/N a justice of peace is included in the prohibition of Section 54 of the Revised
Election Code
Held
Yes. The Court asserted that the term "judge" in Section 54 of the Revised Election
Code encompasses "justice of the peace." The rationale behind this interpretation is
supported by a thorough examination of the historical evolution of the Revised
Election Code, which, according to the Court, serves to validate and clarify the
aforementioned conclusion.

14
Artates vs Urbi
GR No. L-29421
Facts
On September 23, 1952, the land authorities granted a homestead to the spouses Lino
Artates and Manuela Pojas, covered by Patent No. V-12775 and registered under OCT
No. P-572. In 1955, Lino Artates caused injuries to Daniel Urbi, who then filed a civil
case and obtained damages in 1956. Later, in 1961, Urbi purportedly sold the same
homestead to Crisanto Soliven for P2,676.35. This led to Urbi and Soliven taking
possession of the land, depriving the plaintiffs of their rightful share in the rice crops.
Subsequently, in 1962, the Provincial Sheriff conducted a public sale of the land to
satisfy the judgment against Lino Artates, with Urbi being the sole bidder. The Court
of First Instance (CFI) of Cagayan, in a 1963 decision, validated the execution sale,
acknowledging its regularity but deeming the sale to Soliven as simulated. The CFI
ordered Urbi to reconvey the property upon payment of P1,476.35 and other fees by
the plaintiffs.
Issue
W/N the sale is valid
Held
No. Section 118 of the Public Land Law imposes a mandatory restriction on lands
acquired through free or homestead patents for five years. During this period, these
lands cannot be encumbered or alienated except to the government, its institutions, or
duly constituted banking corporations. Furthermore, such lands are exempt from
satisfying any debt incurred within the specified timeframe. This provision aims to
safeguard and retain the land gratuitously granted by the State, ensuring that
homesteaders and their families can secure and enjoy the property, fostering
contentment and contributing to the well-being of society. Any sale violating this

15
provision is deemed null and void, with no legal effect. For purposes of complying
with the law, it is immaterial that the satisfaction of the debt by the encumbrance or
alienation of the land grant made voluntarily, as in the case of an ordinary sale, or
involuntarily, such as that effected through levy on the property and consequent sale at
public auction because in both instances, the spirit of the law would have been
violated.

Aznar vs Yapdianco
GR No. L-1853
Facts
Theodoro Santos, having advertised the sale of his Ford Fairlane 500 in newspapers,
encountered an individual named de Dios who claimed to be the nephew of Vicente
Marella. De Dios asserted Marella's interest in purchasing the car. In Theodoro's
absence, his son Irineo engaged with de Dios. Subsequently, a deed of sale was
executed, and the car's registration was transferred to Marella. However, upon arriving
at Marella's residence, he mentioned a monetary shortfall and sent Irineo and de Dios,
along with an unidentified person, to gather funds from Marella's supposed sister.
Trusting Marella's good faith, Irineo complied, only to have de Dios and the
unidentified person vanish with the car. Santos reported the incident, and Aznar, who
later acquired Marella's land, sought the return of the car through an action for
replevin.
Issue
W/N Santos has the better right to the automobile?
Held
Yes, San tos has a better right to the automobile. Art. 559 of the civil code states that a
person unlawfully deprived of personal property can recover it from the possessor
without reimbursement, except in cases of public auction. The assertion rejects the
equitable principle that usually imposes loss on the party enabling fraud, highlighting
that Art. 559 provides a clear provision for recovery. Marella, from whom Aznar
obtained the title, is deemed not the owner as he acquired possession by stealing, and
the equitable principle is deemed inapplicable in the face of the express provision of
Art. 559.

16
People vs Degamo
GR No. 121211
Facts
Complainant Ellen Vertudazo and her children lived in an Ormoc City apartment.
Unfamiliar with the appellant, she knew him through her brother-in-law. At 1 am on
October 1, 1994, thinking her brother-in-law returned, she opened the door, and the
appellant forced entry with a knife, assaulting and raping her. Warned not to speak, she
reported it later. The trial court, allowing an amendment, included an allegation that
the incident caused the complainant's insanity. Despite the defense's plea, the court
found the appellant guilty of rape, imposing the death penalty.
Issue
W/N the insanity by reason and on occasion of rape of the victim should have a
permanent effect to be considered as qualifying circumstance in the crime of rape
Held
No. The court ruled that the legislator did not specify a requirement for the victim’s
resultant insanity in rape cases to be of a permanent nature or manifested before,
during or after trial. In cases of ambiguity, the history of the law’s enactment, from
introduction to validation, is a primary extrinsic aid considered by the court in this
instant case. Records disclosed that when Senator Sabido initially proposed "perpetual
incapacity or insanity" as a qualifying circumstance in rape cases, the legislative
discussions on Senate Bill No. 21 did not elaborate on the rationale or the degree of
insanity required. Eventually, legislators collectively agreed to include a provision in
the law stating that if a victim becomes insane by reason or on occasion of rape, the
penalty would be reclusion perpetua. The absence of the term “perpetual” in the

17
enacted law indicated a deliberate choice by the legislators that they did not intend that
insanity must be permanent.

National Federation of Labor vs National Labor Relations Commission

GR No. 127718
Facts
The petitioners are employees at the Patalon Coconut Estate in Zamboanga who faced
termination following the enactment of the Comprehensive Agrarian Reform Law (RA
No. 6657). The government aimed to acquire the land for agrarian reform, prompting
the estate's owners (private respondents) to cease its operations. In the absence of
separation pay, the petitioners, represented by their labor group, allege illegal
dismissal. They base their claim on Article 283 of the Labor Code, which outlines
instances where an employer can terminate an employee, including the installation of
labor-saving devices, redundancy, retrenchment to prevent losses, or the closure or
cessation of operations.
Issue
W/N the employer is not liable for separation pay in view of the provisions provided in
Article 283 of the Labor Code
Held
No. The employer is not liable for separation pay. Article 283 of the Labor Code is
applied in cases of closures of establishment and reduction of personnel which is not
the circumstance in the case at bar. The Patalon Coconut Estate was closed down
because a large portion of the said estate was acquired by the DAR pursuant to the
CARP. The severance of employer-employee relationship between the parties came
about involuntarily, as a result of an act of the State. Consequently, complainants are
not entitled to any separation pay. Following the rules in statutory construction, where

18
the word is clear, plan and free from ambiguity, it must be given its literal meaning
and applied without attempted interpretation.

King vs Hernaez
GR No. L-14859
Facts
Macario King, a naturalized Filipino citizen and owner of Import Meat and Produce,
sought to retain 3 Chinese employees. Despite complying with Commonwealth Act
108, the Secretary of Commerce and Industry recommended disapproval, citing RA
No. 1180. The President approved, prompting King and his Chinese employees to file
a petition, asserting the illegality of the rulings given their circumstances and the
constitutional rights of employers and employees.
Issue
W/N the employment of foreigners is non-control positions in retails establishment is
prohibited by the Anti-dummy law
Held
Yes. The Court held that law is clear on what is prohibited in its extent and scope, as
well as because it is in accord with the main objectives outlined in both the Retail
Trade Law and the Anti-Dummy Law - advocating complete nationalization of retail
trade by denying alien ownership, as well as limiting management, operation,
administration and control to Filipino citizens. When the law says you cannot employ
an alien in any position, it can only mean that the employment of a non-Filipino is
prohibited. According to the court, "it is imperative that the law be interpreted in a
manner that would stave off any attempt at circumvention of this legislative purpose."

19
Comendador vs De Villa
GR Nos. 93177 and 96948
Facts
The herein petitioners are officers of the Armed Forces of the Philippines facing
prosecution in the alleged participation in the failed coup d’ etat that took place on
December 1 to 9, 1989. The charges against them are violations of Articles of War
(AW) 67 (Mutiny) and AW 96 (Conduct Unbecoming of an Officers and Gentleman)
and AW 94 (Various Crimes) in relation to Article 248 of the Revised Penal Code
(Murder). A Pre-trial Investigation (PTI) had been constituted where the petitioners
were given several opportunities to file their counter affidavit before being referred to
the General Court Martial (GCM). In GMC No. 14 on May 15, 1990 hearing, the
petitioners manifested that they were exercising their rights to raise a peremptory
challenge against the President and members of the GMC No. 14 by invoking Article
18 of Com Act No. 408. The GMC No. 14 rules, however, that peremptory challenges
had been discontinued under PD No. 39.
Issue
W/N PD 39, which withdrew the right to peremptory challenge members of a military
tribunal, had been inoperative by Proclamation No. 2045 proclaiming the termination
of the state of martial law.
Held
Yes, when martial law ended pursuant to PD 2045, General Order No. 8 was revoked
and military tribunals were dissolved, thus, the purpose for which the PD No. 39
existed no longer applied as it was linked to the conditions and requirements of martial

20
law that were no longer in effect. It is the basic canon of statutory construction that
when the reason of the law ceases, the law itself ceases. Cessante ratione legis, cessat
ipsa lex. This principle is also expressed in the maxim ratio legis est anima: the reason
of law is its soul. Applying this principle, the court holds the withdrawal of the right to
peremptory challenge in PD 39 became ineffective when the apparatus of martial law
was dismantled with the issuance of Proclamation No. 2045. As a result, the old rule
embodied in Article 18 of Com Act No. 408 was automatically revived and now again
allows the right to peremptory challenge. As such, the petition was granted and the
herein petitioners were allowed to exercise the right to peremptory challenge under
Article 18 of the Article of War.

Amatan vs Aujero
GR No.
Facts
A criminal complaint against Rodrigo Umpad for murder was initially charged as
homicide after a preliminary investigation. During arraignment, a plea-bargaining
agreement was reached, wherein Umpad pleaded guilty to the lesser offense of
Attempted Homicide. The judge, following the agreement, found Umpad guilty of
Attempted Homicide. A letter-complaint accused Judge Vicente Aujero of gross
incompetence, ignorance of the law, and misconduct, disputing the verdict for not
aligning with the original charge of Homicide
Issue
W/N the crime of homicide may be reconciled with a plea of guilty to offense of
attempted homicide in view of Section 2, Rule 116 of 1985 Revised Rules of Criminal
Procedure
Held
No. the crime of homicide as defined in Art 249 of the RPC necessarily produces death
while attempted homicide does not. Although the respondent judge argues that he
strictly followed the rule, the conspicuously incongruous outcome should have served
as a warning, indicating the potential for injustice. In the face of a silent or ambiguous
legal provision, judges are encouraged to adopt a solution aligned with conscience and
principles of right and justice. The Civil Code emphasizes the promotion of fairness
and justice when literal application may lead to injustice or results contrary to logic

21
and common sense. In doubt, the intent is to uphold right and justice, reflecting the
principle "fiat justicia ruat coelum" – let justice be done though the heavens fall.

Ursua vs CA
GR No. 112170
Facts
Cesario Ursua, a Community Environment and Natural Resources Officer in
Kidapawan, found himself under investigation in 1989 due to allegations of bribery,
dishonesty, and abuse of authority related to illegal logging activities. The complaint
was initiated by the Sangguniang Panlalawigan, reporting the involvement of Ursua
and other Department of Environment and Natural Resources officials in the
unauthorized cutting of mahogany trees and hauling of illegally-cut logs. During the
investigation, a misrepresentation occurred when Ursua's counsel, Atty. Francis
Palmones, sent a letter requesting complaint details through Ursua's messenger, Oscar
Perez, who used a false name. This led to legal proceedings, with Ursua filing a
demurrer to evidence in 1990, arguing that the prosecution failed to prove his
supposed alias, "Oscar Perez," was distinct from his registered name. Despite Ursua's
contentions, the trial court found him guilty in 1990, a decision later affirmed with
modifications by the Court of Appeals in 1993, imposing a prison term and a fine.
Ursua contested his use of an alias, claiming it was a one-time occurrence with the
consent of Oscar Perez, and challenged the application of the law under which he was
charged.
Issue

22
W/N the isolated use, at one instance, of a name other than the person’s true name to
secure a copy of a document from a government agency, constitutes violation of CA
142 – Anti alias Law
Held
No. The purpose of the Anti-alias Law is to prevent confusion and fraud in business
transactions. Under the rule of statutory construction, statutes are to be construed in
the light of the purposes to be achieved and the evils sought to be remedied. There is a
valid presumption that the legislature did not intend to work a hardship or an
oppressive result, a possible abuse of authority or act of oppression, arming one
person with a weapon to impose hardship on the other. As such, isolated use of
different name is not prohibited by the law, otherwise, injustice, absurdity and
contradiction will result

Co Kim Cham vs Tan Keh

GR No. L-5a
Facts
Manila fell under the occupation of Imperial Japanese Forces in January 1942,
marking the initiation of World War II in the Philippines. During this period, a
proclamation was issued, declaring the continuity of existing laws and institutions,
with public officials instructed to carry out their duties faithfully. The Philippine
Executive Commission (PEC) was subsequently established to coordinate
administrative and judicial functions during the Japanese occupation. In October
1943, the Republic of the Philippines was inaugurated, maintaining the organizational
structure and jurisdiction of courts functioning under the PEC. However, following
the liberation of the Philippines, General Douglas MacArthur proclaimed on October
23, 1944, that all laws, regulations, and processes of governments other than the
Commonwealth were null and void in areas liberated from enemy control. This
proclamation became a focal point in a legal dispute, as Judge Arsenio P. Dizon
refused to continue judicial proceedings initiated under the Japanese occupation,
asserting that MacArthur's proclamation invalidated those proceedings and judgments.
Issue

23
W/N the proclamation issued on October 23, 1944 by General MacArthur has
invalidated all judgments, judicial acts and proceedings of the courts
Held
No. Taking into consideration the well-known principles of international law, all
judgments and judicial proceedings of de facto governments during the Japanese
military occupation were good and valid before and remained so valid after liberation
of the Philippines. Therefore, it is evident that the proclamation of General MacArthur
of October 23, 1944 has not invalidated the judicial acts and proceedings of the courts
of justice in the Philippines that were continued by the Philippine Executive
Commission and the Republic of the Philippines during the Japanese military
occupation.

Salvacion vs Central bank of the Philippines

GR No. 94723
Facts
American tourist Greg Bartelli lured and detained 12-year-old Karen Salvacion in his
apartment, subjecting her to multiple rapes before her rescue. Bartelli faced criminal
charges, including serious illegal detention and four counts of rape, while the
petitioners filed a damages case with a plea for preliminary attachment. Despite the
granted attachment, China Banking Corporation, where Bartelli had an account, cited
the secrecy of bank deposits and invoked Section 113 of Central Bank Circular No.
960. The petitioners then sought declaratory relief, contending that Section 113,
exempting foreign currency deposits from court orders, violated their right to garnish
Bartelli's account for judgment satisfaction.
Issue
W/N Sec. 113 of Central Bank Circular No. 960 and Section 8 of the Foreign Currency
Deposit Act shall be made applicable to a foreign transient.
Held
No. Foreign currency deposit made by a transient or tourist is not the type encouraged
or protected by PD Nos. 1034 and 1035, designed for longer-term investments.

24
Respondent Greg Bartelli, identified as a tourist or transient, deposited his dollars with
China Banking Corporation for safekeeping during his brief stay in the Philippines.
The application of the law should align with justice, wherein ruling of Section 113 of
Central Bank Circular No. 960 as applicable to a foreign transient would result in
injustice, particularly to a citizen aggrieved by such a foreign guest like Bartelli. This
would negate Article 10 of the New Civil Code which provides that "in case of doubt
in the interpretation or application of laws, it is presumed that the lawmaking body
intended right and justice to prevail. "Ninguno non deue enriquecerse tortizeramente
con dano de otro." Simply stated, when the statute is silent or ambiguous, this is one of
those fundamental solutions that would respond to the vehement urge of conscience..
Consequently, the court deems the provisions of Section 113 of CB Circular No. 960
and PD No. 1246, amending Section 8 of R.A. No. 6426, as inapplicable to this case
due to its unique circumstances.

Felife, Sr. vs Leuterio

GR No. L-4606
Facts
In an oratorical competition conducted in Naga, Camarines Sur, Nestor Nosce received
the top honor from the judging panel, while Emma Imperial was awarded second
place. Emma later appealed to the Court of First Instance in the province, asserting that
a judge had made an error in assessing her performance. Following a hearing and
despite objections from four contest judges, the Court reversed the initial decision and
declared Emma the winner. This led to a special civil action questioning the Court's
authority to alter the board's original verdict.
Issue
W/N the court has authority to reverse the award of the board of judges
Held
No. the judiciary has no power to reverse the award of the board of judges of an
oratorical contest. For that matter it would interfere in literary contests, beauty contests
and similar competitions. The responding judge, upon assuming jurisdiction, argued
that where there is a wrong, there is a remedy, emphasizing the general jurisdiction of
courts of first instance. However, the flaw in this reasoning lies in the assumption that

25
Emma Imperial suffered a wrong at the hands of the entire board of judges. If any error
occurred, it was at most the fault of one judge. It's crucial to distinguish between
"error" and "wrong," as the latter refers to the deprivation or violation of a right.
Contestants have no inherent right to the prize unless officially declared winners by the
board of referees or judges. Even if Imperial experienced some loss or injury, legal
principles recognize instances of "damnum absque injuria." In this case, unless fraud
or malice is proven, her action should be directed against the individual judge or
judges responsible for any fraudulent or malicious conduct, rather than implicating the
entire board.

Matabuena vs Cervantes
GR No. L-28771
Facts
Felix Matabuena donated a property to his common-law partner, Petronila Cervantes.
They married in March 1962, and five months later, Felix passed away intestate.
Petronila and Cornelia, Felix's sister, were the surviving relatives. Cornelia filed a case
to reclaim the donated property, citing Article 133 of the Civil Code, which voids
donations between spouses during marriage. The trial court argued that the prohibition
didn't apply because the donation occurred when Felix and Petronila were not yet
married, merely cohabiting.
Issue
W/N the ban on donation between spouse during the marriage apply to common-law
relationship?
Held
Yes. It is a fundamental principle in statutory construction that what aligns with the
spirit of the law is equally significant as its written text. Given that the prohibition on

26
spousal donations during marriage aims to prevent undue influence, the court asserts
that this prohibition logically extends to common-law relationships.

Romualdez vs Sandiganbayan
GR No. 152259
Facts
People of the Philippines, represented by the PCGG, filed a petition accusing the
defendant, the brother-in-law of former President Marcos, of violating Section 5 of
RA 3019. The accused, being related by affinity within the third civil degree to
Marcos, was alleged to have willfully and unlawfully intervened in a contract between
the National Shipyard and Steel Corporation (NASSCO), a government-owned
corporation, and the Bataan Shipyard and Engineering Company (BASECO), a
private corporation majority-owned by Marcos. The intervention involved NASSCO
selling, transferring, and conveying its ownership, titles, and interests in equipment,
facilities, and assets located at Engineer Island Shops to BASECO for P5,000,000.
The accused was charged with evident bad faith for promoting his self-interest and
that of others in this transaction.
Issue

27
W/N Section 5 of the RA No. 3019 is unconstitutional on grounds that the said
provision is vague as it does not specify what acts are punishable under the
aforementioned term.
Held
NO. The court ruled that every statute is presumed valid, and the burden of proving its
invalidity rests on the party challenging it. The court emphasized that any reasonable
doubt about the validity of the law should be resolved in favor of its constitutionality.
In this case, the petitioner failed to overcome the presumption of constitutionality, and
the court rejected the claim that Section 5 of RA 3019 was vague. The court clarified
that a statute is not rendered uncertain and void simply because general terms are
used, and the term "intervene" can be understood through simple statutory
construction. The court concluded that the challenged provision is not vague, and the
doctrines of overbreadth and void for vagueness are not applicable.

People vs Santiago
GR No. L-17663
Facts
This is a crime of libel committed by Accane Man Terotin against Arsenio H. Lacson.
The accusation states that, during a political speech on October 5, 1959, using an
amplifier system before an audience of approximately a hundred people, Terotin
maliciously implicated Lacson in the rape of a woman at Aroma Café and another
City Hall employee at Shellborne Hotel. The defendant sought to quash the
information, contending that the alleged crime was oral defamation, which had
already prescribed as the information was filed on August 11, 1960, more than 6
months after the purported commission on October 5, 1959. The crime of oral
defamation, according to the defendant, had already prescribed on April 5, 1960.
Issue
W/N amplifier system is considered a means “similar” to “radio” to convey
defamatory statement

28
Held
No. The court ruled against considering an "amplifier system" as a means "similar" to
"radio." The contention was deemed untenable, primarily because the transmission of
words through an amplifier system involves conducting wires, unlike radio's
transmission via electromagnetic waves without conducting wires. Additionally, the
court emphasized that the term "radio" in Article 355 should be understood in
connection with associated terms, all of which have a common characteristic – their
permanent nature as a means of publication. The court highlighted the distinction
between the permanent nature of radio and other forms of publication, rejecting the
prosecution's argument regarding the similarity of an "amplifier system" to radio in
the context of libel.

Ramirez vs CA
GR No. 93833
Facts
Socorro D. Ramirez sued Ester S. Garcia in Quezon City for damages, claiming Garcia
insulted and humiliated her in an offensive manner. Ramirez presented a transcript
from a recorded confrontation. In response, Garcia filed a criminal case in Pasay City,
alleging a violation of Republic Act 4200, which prohibits wiretapping and related
violations of private communication. Ramirez argues that Republic Act 4200, which
deals with wiretapping, doesn't apply when one of the conversation's participants is the
one doing the recording. She emphasizes that the law is aimed at unauthorized tapping
by an external party. Ramirez also insists that the content of the conversation should be
specified in the legal charges for it to be a violation of R.A. 4200. Moreover, she
claims that the law addresses the taping of a "private communication," not a "private
conversation," asserting that her secret recording wasn't illegal under R.A. 4200.
Issue

29
W/N the recording of private conversation without consent of both parties constitutes
violation of RA 4200
Held
Yes. R.A. 4200 is clear and unambiguous that any person recording a private
communication without the consent of both parties are illegal. Legislative intent is
determined principally from the language of a statute. Where the language of a statute
is clear and unambiguous, the law is applied according to its express terms, and
interpretation would be resorted to only where a literal interpretation would be either
impossible or absurd or would lead to an injustice

Pilar vs. COMELEC

GR No. 115245
Facts
The plaintiff in this case is a candidate who subsequently withdrew his candidacy
without submitting the required statement of contributions and expenditures. Section
14 of Republic Act No. 7166 explicitly mandates that "every candidate" is obligated to
file this statement, emphasizing a universal requirement for all candidates participating
in elections. The petitioner claims he can't be held responsible for not filing a
statement of contributions and expenditures as he withdrew his candidacy just three
days after filing. He argues that the law requires actual participation in the political
contest, either winning or losing, to be considered a candidate subject to such
obligations.
Issue
W/N the petitioner is still liable for the violation of Section 14 of RA 7166 even if he
withdrew his candidacy

30
Held
Yes. The petitioner shall remain liable for violating Section 14 of RA No. 7166 despite
withdrawing his candidacy. The law explicitly mandates every candidate, without
specifying their status, to file a statement of contributions and expenditures.
Additionally, the Omnibus Election Code underscores that filing or withdrawing a
certificate of candidacy doesn't affect liabilities incurred. In this case, Pilar, having
initially filed a candidacy, is obligated to fulfill the required statements and forms, as
the law doesn't distinguish between active candidates and those who withdrew. The
principle applied is that where the law doesn't distinguish, courts should not
distinguish.

Carandang vs Santiago
GR No. L-8238
Facts
Tomas Valenton, Jr. was convicted of frustrated homicide against Cesar Carandang.
Carandang filed a civil case for damages against Valenton, Jr. and his parents. The
defendants moved to suspend the civil trial until the criminal appeal concluded. The
judge agreed, invoking Article 33 of the Civil Code, which allows a separate civil
action for damages in cases of defamation, fraud, and physical injuries. Despite the
wound being a bodily injury, the court clarified that the crime was frustrated homicide
due to the intent to kill. The petition for certiorari challenges the decision to await the
outcome of the criminal appeal before proceeding with the civil case.
Issue

31
W/N the physical injuries under Article 33 of the new Civil Code means any physical
injuries in the RPC, or any physical injury or bodily injury inflicted with or without
intent to kill.
Held
The court ruled that the term "physical injuries" is understood to mean bodily injury,
not the crime of physical injuries, to maintain consistency in the interpretation of terms
within the same aforementioned article of the new civil code since "defamation," and
"fraud," are used in their ordinary sense. Since the Revised Penal Code lacks specific
provisions defining offenses using these terms, the court interprets them in their
generic sense. Following the rule of statutory construction, the meaning of unclear or
ambiguous word should be determined by considering the words with it is associated
in the context. The meaning of questionable words or phrases in a statute may be
ascertained by reference to the meaning or words of phrases associated with it and may
be known from accompanying words.

Vera vs Cuevas
GR Nos. L-33693-94
Facts
Private respondents, engaged in the production and distribution of filled milk products
in the Philippines, market their items under different brand names. The Commissioner
of Internal Revenue (CIR) instructed them to include a specific inscription on their
products in accordance with Section 169 of the Tax Code. This inscription, regarding
skimmed milk, states that the product is not suitable for infants under one year of age.
Failure to comply within fifteen days would lead to penalties. The Court of First
Instance in Manila ruled in favor of the private respondents, directing the CIR to
permanently refrain from demanding the specified label on their products.

32
Additionally, the FairTrade Board was ordered to permanently abstain from
investigating the respondents regarding their filled milk products.
Issue
W/N the skimmed milk is included in the scope of Section 169 of the tax code
Held
No, Section 169 of the Tax Code does not extend to filled milk. The specific terms
"skimmed milk" in the heading and "condensed skimmed milk" in the text of the
mentioned section limit the application of the general clause "all milk, in whatever
form, from which the fatty part has been removed totally or in part." This limitation is
guided by the rule of ejusdem generis, where general terms are restricted by specific
terms in the statute. The distinction between skimmed milk and filled milk lies in the
latter having the fatty part replaced with refined coconut oil or corn oil. Therefore,
assuming Section 169 applies to both skimmed and filled milk is neither immediate
nor safe. Moreover, findings indicate that the filled milk products are safe, nutritious,
and suitable for infants, challenging the application of Section 169 and emphasizing
the potential deprivation of property without due process of law.

Mutuc vs COMELEC
GR No. L-32717
Facts
Mutuc, a candidate for the Constitutional Convention, contested a directive from the
Commission on Elections (COMELEC) that prohibited him from using jingles in his
mobile units equipped with sound systems and loudspeakers during his campaign. The
petitioner argued that such an order violated his constitutional right to freedom of
speech. The COMELEC justified the prohibition based on a provision in the
Constitutional Convention Act, contending that the jingle in question was tangible
propaganda material subject to confiscation. The Court, after a prompt hearing and
deliberation, issued a resolution granting the writ of prohibition, emphasizing the

33
absence of statutory authority for the COMELEC's ban. The Court invoked the
doctrine of ejusdem generis, highlighting that the construction placed by the
COMELEC raised serious doubts about the validity of the directive and its impact on
the petitioner's freedom of speech.
Issue
W/N the usage of the jingle by the petitioner form part of the prohibition invoked by
the COMELEC from the Constitutional Convention Act.
Held
No. The Commission on Elections (COMELEC) lacked the authority to impose the
ban on political jingles under the Constitutional Convention Act. While the
COMELEC argued that the Act prohibited the distribution of electoral propaganda
gadgets, listing various items and concluding with "and the like," the Court disagreed.
Applying the principle of ejusdem generis, which states that general words following a
specific enumeration apply only to things of the same kind or class, the Court
emphasized that the Act was concerned with the distribution of gadgets as
inducements for favorable votes. The Court concluded that the general words "and the
like" did not justify the COMELEC's order against political jingles.

E.B. Villarosa & Partner Co., Ltd. Vs Benito

GR No. 136426
Facts
E.B. Villarosa & Partner Co., Ltd. and the private respondent entered into an
agreement to develop land in Cagayan de Oro. Disputes led to the respondent filing a
case in Makati, alleging a breach of contract. Despite a summons being served at the
wrong office in Cagayan de Oro, the Sheriff's Return of Service indicated proper
service at a new office address in the same city.
Issue
W/N the trial court acquired jurisdiction over the person of petitioner upon service of
summons on its Branch Manager.

34
Held
NO. The court held that the service of summons on the branch manager in Cagayan de
Oro instead of the general manager in Davao City is deemed improper, leading to the
trial court lacking jurisdiction over the petitioner. The defendant's belated motion to
dismiss doesn't confer jurisdiction, as voluntary appearance is now equivalent to
summons service. The previous practice of challenging jurisdiction via a motion to
dismiss has been replaced by a stricter rule in Section 20 of Rule 14 (1997 Rules).
Filing a motion to dismiss objecting to the court's jurisdiction is not a submission to
jurisdiction due to the absence of proper summons service, rendering any proceedings
by the trial court null and void.

Cagayan Valley Enterprises, Inc. vs CA

GR No. 78413
Facts
La Tondeña, Inc. (LTI) registered its 350 c.c. white flint bottles for "Ginebra San
Miguel" under Republic Act No. 623. LTI sued Cagayan Valley Enterprises, Inc. for
using identical bottles without consent, filling them with "Sonny Boy" liquor, and
violating RA 623. Cagayan argued LTI lacked a cause of action and that its hard liquor
products weren't covered. LTI obtained a TRO, but the trial court ruled in Cagayan's
favor. The CA reversed, permanently enjoining Cagayan from using the bottles. RA
623 protects registered bottles, and unauthorized use is unlawful, ensuring the
manufacturer's rights.

35
Issue
W/N LTI's bottles for Ginebra San Miguel are covered by the protection of RA 623 as
amended by RA 5700
Held
Yes. The court rejected the petitioner's claim that hard liquor is not covered by
Republic Act No. 623. It emphasized that "other lawful beverages" encompasses all
beverages not prohibited by law, including hard liquor. The court highlighted the law's
purpose: protecting public health, preventing disease spread, and safeguarding the
property rights of the industry. The rule of ejusdem generis, limiting the law's
coverage, was deemed inapplicable, ensuring the law's broader intent prevailed. The
court emphasized the Philippine Patent Office's registration, confirming the bottles'
eligibility for protection under RA 623 for gin, Ginebra San Miguel.

U.S. vs Santo Nino

GR No. 5000
Facts
On or about the 16th day of August, 1908, in the City of Manila, Philippine Islands,
the said Victor Santo Nino, voluntarily, unlawfully, and criminally, had in his
possession and concealed about his person a deadly weapon, to wit: One (1) iron bar,
about 15 inches in length provided with an iron ball on one end and a string on the
other to tie to the wrist, which weapon had been designed and made for use in fighting,
and as a deadly weapon. Act No. 1780 regulates firearms in the Philippines, and
Section 26 prohibits carrying concealed deadly weapons unless licensed. The court
sustained a demurrer, applying the rule of ejusdem generis, arguing that "other deadly

36
weapon" should be of the same kind as the specific weapons listed. This rule interprets
general terms following specific ones in the same act to encompass things or persons
of the kind designated by the specifics.
Issue
W/N the deadly weapon includes an unlicensed revolver
Held
Yes. Carrying the mentioned weapon would indeed violate the statute, as indicated by
the proviso, which expresses an intention to extend the prohibition to weapons beyond
those specifically listed. Despite the court below's view that carrying a concealed
revolver wouldn't violate the Act, the ruling is reversed. The rule of ejusdem generis is
used to interpret legislative intent, but it gives way when other parts of the law clearly
contradict its result. Here, the proviso makes it evident that the legislature intended to
include unlicensed revolvers in the Act's prohibition, extending beyond the initially
specified weapons. The case is remanded for further proceedings.

Office of Ombudsman vs Masing

GR No. 165416
Facts
In G.R. NOS. 165416 and 165731, Florita A. Masing and Jocelyn A. Tayactac faced
administrative charges for financial misconduct. Despite a motion to dismiss based on
DECS jurisdiction, the Ombudsman found them guilty in 2000. The Court of Appeals
reversed this decision in 2004, prompting the Office of the Ombudsman to file a
motion to intervene, which was denied. In G.R. No. 165584, Masing faced additional
charges, leading to a suspension. The Court of Appeals set aside the Ombudsman's
decision in 2003, granting Masing her salary during the contested suspension. The
Ombudsman contended that the term "recommend" should be construed literally,

37
signifying an advisory role, while the Office of the Ombudsman asserted that it should
be interpreted in conjunction with the phrase "and ensure compliance therewith."
Meanwhile, the respondent relying on the precedent set in Tapiador v. Office of the
Ombudsman, the Ombudsman's findings should be considered as recommendations
without the authority to directly impose administrative sanctions, specifically dismissal
from government service.
Issue
W/N the Office of the Ombudsman may directly discipline public school teachers and
employees
Held
Yes. The court acknowledged the explicit authority granted to the Ombudsman in
Article XI, Section 12 and delineated its powers in Section 13 of the 1987
Constitution, emphasizing a more active role in law enforcement compared to its
predecessor under the 1973 Constitution. Contrary to the argument that the
Ombudsman's orders are merely advisory, the court highlighted that its authority to
remove, suspend, demote, fine, or reduce salary is not recommendatory but mandatory.
The ruling underscored the Ombudsman's clear mandate as the primary complaints and
action center against misconduct by public officers, as mandated by Section 13(1),
Article XI of the Constitution.

Lopez vs CA
GR No. 144573
Facts
Private respondent Atty. Romeo A. Liggayu, PCSO's Legal Department Manager,
faced administrative charges for issuing a subpoena without authority and was
suspended for six months without pay by the Office of the Ombudsman. Despite a
denial of his motion for reconsideration, he filed a petition for review before the Court
of Appeals, seeking a restraining order against the Ombudsman's decision. The Court
of Appeals granted a Temporary Restraining Order (TRO), preventing the
Ombudsman from enforcing the suspension. Petitioners argued they were not parties
when the TRO was issued and that it became moot due to Liggayu's suspension. The

38
Court of Appeals, citing a violation of the equal protection clause, granted a Writ of
Preliminary Mandatory Injunction, reinstating Liggayu pending appeal. The
petitioners contested this, claiming the Court of Appeals abused its discretion.
Issue
W/N the decision of CA violates the equal protection clause for being unfair to
government employees charged under the Civil Service Law, where the decisions in
disciplinary cases are immediately executory.
Held
No. The Court of Appeals did not violate the equal protection clause by allowing an
appeal in a case where the penalty imposed exceeded one month's suspension or a fine
equivalent to one month's salary, as stated in Rule III Section 7 of the Provisionary
Rules of the Office of the Ombudsman. The provision allows the respondent the right
to appeal unless the penalty is within the specified limits of censure, reprimand, or
suspension of not more than one month, or a fine not equivalent to one month's salary.
Since the private respondent appealed a six-month suspension, the stay of execution
of the penalty is deemed a matter of right.

Ang Bagong Bayani vs COMELEC

GR No. 147589
Facts
Petitioners are disputing COMELEC's Omnibus Resolution No. 3785, which
sanctioned the involvement of 154 organizations and parties in the 2001 party-list
elections. They assert that the party-list system was designed to favor marginalized and
underrepresented groups, making the inclusion of political parties objectionable. The
Solicitor General contends that RA 7941 permits political parties to participate,
emphasizing that the eligibility extends to all registered national, regional, and sectoral
parties or organizations.
Issue

39
W/N political parties may participate in the party-list elections?
Held
Yes. In accordance with RA 7941, the respondents cannot be barred from participating
based on their status as political parties. The Constitution also provides that members
of the House of Representatives may “be elected through a party-list system of
registered national, regional and sectoral parties or organizations.”

Republic Flour Mills vs Comm. Of Customs

GR No. 28463
Facts
Republic Flour Mills, Inc. seeks a review of a decision by the Court of Tax Appeals,
challenging the imposition of wharfage dues amounting to P7,948.00 by the
Commissioner of Customs. The company argues that bran and pollard, byproducts of
milling imported wheat, should be excluded from the term "products of the
Philippines" in Section 2802 of the Tariff and Customs Code. The Court of Tax
Appeals, however, upholds the assessment, emphasizing that the wharfage dues are
applicable upon the discharge of exported goods by a vessel engaged in foreign trade,
irrespective of the use of government or private wharves.

40
Issue
W/N the "product of the Philippines" of Section of 2802 excludes pollard and bran,
thus collection of wharfage dues was in accordance with the law.
Held
No. The contention that "Product of the Philippines" in Section 2802 of the Tariff and
Customs Code excludes pollard and bran is rejected, and the collection of wharfage
dues is deemed in accordance with the law. Section 2802 explicitly includes both
imported articles and products of the Philippines, making it clear that goods produced
within the country fall under its terms. The petitioner, engaged in flour manufacturing,
exports bran and pollard, which are considered byproducts of milling. The court
emphasizes the fundamental duty to apply the law, and in this case, the clear language
of Section 2802 mandates compliance without the need for intricate interpretation.

Canet vs Decena
GR No. 155344
Facts
Petitioner Rolando Canet, a cockpit operator in Bula, Camarines Sur, was initially
allowed to operate under Resolution No. 049. In 1999, the Sangguniang Bayan passed
Ordinance No. 001 to regulate cockpits, but Mayor Julieta Decena denied it, stating it
lacked specific rules and regulations. The ordinance was shelved indefinitely. When
Canet applied for a mayor's permit, it was denied by Decena, who argued that the
Local Government Code vested licensing authority in the Sangguniang Bayan. Canet,
relying on Resolution No. 049 and local tax ordinances, sued Decena, seeking a
permit for his cockpit operation.

41
Issue
W/N Decena, in her capacity as Municipal Mayor, can be compelled to issue the
necessary business permit to petitioner without a municipal ordinance that would
empower her to do so.
Held
No. To compel Decena to issue the mayor's permit would not only be a violation of
the explicit provisions of Sec. 447 of the Local Government Code of 1991, but would
also be an undue encroachment on respondent’s administrative prerogatives. Hence,
there being in effect no ordinance allowing the operation of a cockpit, Resolution No.
049, authorizing Canet to establish, operate and maintain a cockpit in Bula,
Camarines Sur cannot be implemented. Also, the municipal tax ordinances relied
upon by Canet contain general provisions for the issuance of business permits but do
not contain specific provisions prescribing the reasonable fees to be pain in the
operation of cockpits and other game fowl activities. Even on the assumption that
there is in fact a legislative gap caused by such an omission, neither could the Court
presume otherwise and supply the details thereof, because a legislative lacuna cannot
be filled by a judicial fiat

City of Baguio vs Marcos

GR No. 26100
Facts
The case involves the reopening of cadastral proceedings, specifically Civil
Reservation Case No. 1, GLRO Record No. 211, initiated on April 12, 1912, for the
Baguio Townsite. The contested land was declared public by a final decision in CRC
No. 1 on November 13, 1922. Respondent Belong Lutes filed a petition on July 25,
1961, seeking to reopen CRC No. 1 for a parcel of land he claims. Lutes argued that he
and his predecessors had continuous possession since Spanish times, paying taxes, and
that his illiterate Igorot predecessors were unaware of the cadastral proceedings,
justifying the late filing. However, petitioners challenged Lutes' petition, contending it

42
exceeded the 40-year period preceding the approval of Republic Act No. 931, which
allowed claims for parcels declared public land due to failure to file within the
statutory period.
Issue
W/N the petition filed by respondent to reopen Civil Reservation Case No. 1, GLRO
Record No. 211 of the Cadastral Court of Baguio was within the 40 years next
preceding the approval of RA No. 931
Held
Yes. The court held that the petition to reopen the cadastral proceedings fell within the
40-year period preceding the approval of R.A. No. 931. The apparent inconsistency
between the title and body of the statute, the court resolved it by interpreting the
legislative intent. Despite the body of the statute suggesting a 40-year period from the
institution of the cadastral proceedings, the court considered the title of R.A. No. 931,
which emphasized claims arising from judicial decisions within the same time frame.
Following the rule of statutory construction, using the title as a guide to determine
legislative intention, as the Constitution mandates that a law's subject must be
expressed in its title. The court concluded that Congress intended to give effect to the
title of R.A. No. 931, aligning with the principle that statutory interpretation should
fulfill legislative intent even if a literal reading may suggest otherwise.

People vs Rivera
GR No. 38215 and 38216
Facts
Rivera signed and swore to a complaint accusing Vito and Moreno the crime of theft.
According to the information, the items stolen were a white American suit with one
eyeglasses amounting to P30, one buntal hat which costs P3, and two buttons which
cost P3 each, with the total amount of P39. The justice of the peace dismissed the
case. After which, Vito and Moreno filed complaints against Rivera, charging him
with incriminating innocent people, which falls under Article 363 of the Revised
Penal Code. Rivera objected and claimed that the facts alleged did not fall under
Article 363 of the Revised Penal Code, and that, Article 363 of the Codigo Penal does

43
not appear in the Revised Penal Code. Hence, there is no offense embracing
acusacion o denuncia falsa.
Issue
W/N Rivera can be charged guilty of incriminating innocent people under Article 363
of the Revised Penal Code
Held
No. The crime Rivera was accused of is not explicitly stated in the Revised Penal
Code, although the crime of indictment of the innocent is included in the Old Penal
Code. Article 363 of the Old Penal Code talks about punishment for false
prosecutions. In the Revised Penal Code, Article 363 pertains to punishment for any
act which may tend directly to cause a false prosecution. This provision is limited to
acts of planting evidence which do not constitute false prosecution but tend directly to
cause false prosecutions. It is well settled law that where the text of a statute is clear,
it is improper to resort to a caption or title to make it obscure. Such secondary sources
may be resorted to in order to remove, not to create doubt. It seems the more
reasonable and sensible interpretation to limit article 363 of the Revised Penal Code
to acts of "planting" evidence and the like, which do not in themselves constitute false
prosecutions but tend directly to cause false prosecutions. It is a well settled rule that
statutes should receive a sensible construction, such as will give effect to the
legislative intention and so as to avoid and unjust or an absurd conclusion. If we
extended said article by interpretation to administrative and judicial proceedings, it is
apparent that we would open the door to a flood of prosecutions in cases where the
defendants were acquitted. There is no reason to believe that the Legislature intended
such a result.
Aboitiz Shipping vs City of Cebu
GR No. L-14526
Facts
Ordinance No. 207 was purportedly enacted by the Municipal Board on August 14,
1956 and approved by the City Mayor on the following August 27 where plaintiffs
were made to PA wharfage charges under protest since September 1, 1956 and on
May 8, 1957. The plaintiffs filed an action in the Court of First Instance of Manila to
have the said void, its enforcement enjoined in so far as the wharves, docks and
ordinance declared other landing places belonging to the National Government
were concerned, and all the amounts thus far collected by defendants refunded to

44
them. Appellee alleges that the Municipal Board's authority to pass the ordinance is
claimed by them under section 17 (w) of the charter of the City of Cebu, which grants
them the legislative power “To fix the charges to be paid by all watercraft landing at
or using public wharves, docks, levees, or landing places.
Issue
W/N the City of Cebu, under its charter, may provide by ordinance for the collection
of wharfage from vessels that dock at the public wharves of piers located in said city
but owned by the National Government.
Held
No. The right to collect the wharfage belongs to the National Government. It is
unreasonable to conclude that the legislature, simply because it employed the term
"public wharves" in section17 (w) of the charter of the City of Cebu, thereby
authorized the latter to collect wharfage irrespective of the ownership of the wharves
involved. The National Government did not surrender such ownership to the city;
and there is no justifiable ground to read into the statute an intention to burden
shipowners, such as appellants, with the obligation of paying twice for the same
purpose. Legislative intent must be ascertained from a consideration of the statute as a
whole and not of an isolated part or a particular provision alone. This is a cardinal rule
of statutory construction. For taken in the abstract, a word or phrase might easily
convey a meaning quite different from the one actually intended and evident when the
word or phrase is considered with those with which it is associated. Thus, an
apparently general provision may have a limited application if viewed together with
other provisions. Hence, Ordinance No. 207 of the City of Cebu is declared null and
void, and appellees are ordered to refund to appellants all amounts collected
thereunder and to refrain from making such collection.
Agcaoili vs Suguitan
GR No. L-24806
Facts
Julio Agcaoili was appointed as justice of the peace for Laoag municipality in the
Province of Ilocos Norte on March 25, 1916, with the authority to hold the office and
its accompanying powers, privileges, and emoluments, subject to the conditions
prescribed by law. At the time of his appointment, Act No. 2041 dictated that justices
of the peace, including Agcaoili, would hold office during good behavior. However,
on March 17, 1923, the Philippine Legislature enacted Act No. 3107, which, in section

45
203, stipulated that justices and auxiliary justices of the peace would serve until
reaching the age of sixty-five. Consequently, on April 9, 1923, the Undersecretary of
Justice informed Agcaoili that, due to the amendment of the Administrative Code, he
had ceased to be a justice of the peace.
Issue
W/N Section 216 applies to public officers
Held
No. A semicolon in the English language serves as a punctuation mark to signify a
separation in the relation of thought, a degree greater than that expressed by a comma.
It is used to continue the expression of a thought, not to introduce a new idea. Both
commas and semicolons are employed to divide sentences, with the semicolon
providing a slightly more pronounced division. The punctuation in law aids in
determining the true meaning of a statute. In the context of Section 216, all provisions
preceding the semicolon pertain to corporations, and what follows the semicolon also
concerns the same subject matter, specifically officers of a corporation.

Feliciano vs Aquino
GR No. 10201
Facts
After being proclaimed as the elected mayor of Concepcion, Tarlac, the respondent
faced quo warranto proceedings initiated by the petitioner just four days later. The
challenge was based on the contention that the respondent, at the time of his election,
was not yet 23 years old. The respondent argued that the age requirement should be
met at the time of assuming office and not necessarily at the time of the election,
emphasizing the impact of a punctuation change in the 1951 Revised Administrative

46
Code. Despite the respondent's argument, the lower court ruled in favor of the
petitioner, leading to the initiation of this petition.
Issue
W/N the proclamation of respondent as elected mayor is correct
Held
The fundamental rule of statutory construction emphasizes the significance of
punctuation marks, asserting that they should not be ignored unless there is a
compelling reason to do so. Punctuation serves as a tool to aid in interpreting the
language of a statute but cannot override the clear and intelligible meaning of written
words. In this case, there is no evident reason to deviate from the explicit requirement
that candidates for various elective offices must meet the age qualification "at the time
of the election." The law's sudden change in the requirement for municipal officers is
not justified. It is evident that the mention of eligibility or ineligibility in the statute
pertains to participating in the election, not the capacity to assume office. The lower
court's decision is upheld, declaring the respondent's election as unlawful and illegal.

People vs Subido
GR No. 21735
Facts
Abelardo Subido was found guilty of libel against Mayor Arsenio Lacson and was
initially sentenced by the trial court to three months of arresto mayor, a fine of
P500.00, and indemnity of P10,000.00, with subsidiary imprisonment in case of
insolvency. Subido appealed to the Court of Appeals (CA), resulting in a modification
of the judgment where the CA eliminated the three months of arresto mayor and
reduced the indemnity to P5,000.00. Upon returning the case to the trial court for

47
execution, Subido sought to cancel his appeal bond, arguing that he couldn't be
subjected to subsidiary imprisonment if he couldn't pay the prescribed fine and
indemnity, as it was not expressly provided in the judgment.
Issue
W/N Subido is required to serve the indemnity in the form of subsidiary imprisonment
in case of insolvency.
Held
No. The Supreme Court ruled that Abelardo Subido is obligated to undergo subsidiary
imprisonment in case of insolvency for the fine imposed. However, the Court clarified
that he is not required to serve subsidiary imprisonment for the indemnity in case of
insolvency. The Court emphasized that the punctuation marks, specifically the comma
used to separate the clause "with subsidiary imprisonment in case of insolvency,"
played a crucial role in the construction of the statute. The separation indicated the
court's intention for the clause to encompass both the fine and indemnity. Despite this,
the Court applied Article 39 of the Revised Penal Code retroactively, guided by Article
22 of the RPC, which exempts an accused person from subsidiary imprisonment for
insolvency regarding the civil liability. Consequently, Subido is not compelled to
undergo subsidiary imprisonment for the indemnity but is mandated to serve it for the
fine in case of insolvency.

In Re State of Jonhson
GR No. L-12767
Facts
Emil Johnson, a Swedish native naturalized in the U.S., passed away in Manila,
leaving a will disposing of his estate. The will, handwritten and signed by Johnson but
with only two witnesses instead of the required three under Sec. 618 of the Code of
Civil Procedure, was deemed non-compliant with the law. A petition filed on February
9, 1916, in the Court of First Instance of Manila City argued that Johnson, being a U.S.
citizen at the time of his death, and the will being executed according to U.S. law,

48
should be probated under Sec. 636 of the Code of Civil Procedure. After witness
examinations, the will was declared legal and admitted to probate on March 16, 1916.
However, about three months later, Ebba Ingeborg Johnson's attorneys entered an
appearance, seeking to annul the probate decree to establish her claim as the sole
legitimate heir of Emil Johnson. The motion was denied, with Ebba Ingeborg asserting
that Sec. 636 applies only to wills of aliens, emphasizing the non-capitalization of
"state" in the section. She argued that Section 636 is not applicable to the will of a U.S.
citizen residing in Manila, not Illinois, U.S.A.
Issue
W/N Section 636 of the Code of Civil Procedure is applicable to the case at bar
Held
Yes. The Court clarified that the phrase "another state or country" encompasses the
United States and the States of the American Union, extending beyond wills of aliens.
It emphasized that punctuation and capitalization play a secondary role in interpreting
statutory language and cannot override the clear meaning of the written words. Despite
living in Manila, Johnson was a U.S. citizen at the time of his death in the state of
Illinois. Therefore, the contested will is admissible for probate under the provision, as
it aligns with the law of the State of Illinois.

Unabia vs City Mayor

GR No. L-8759
Facts
The petitioner, employed as a foreman in the Group Disposal of the Office of the City
Health Officer in Cebu City, earned P3.90 per day. On June 16, 1953, the City Mayor
removed him from his position, subsequently replaced by Perfecto Abellana and later
by Pedro E. Gonzales. Notably, before June 16, 1953, the Group Disposal Division,
along with its personnel, was shifted from the City Health Department to the Office of
the City Engineer. In April 1954, the petitioner sought reinstatement, yet the

49
respondents did not heed his plea. The Court of First Instance of Cebu determined that
the petitioner, categorized under the unclassified service as per Section 670 of the
Revised Administrative Code, faced a violation of Section 694 of the Revised
Administrative Code and Section 4 of Article XII of the Constitution. An argument
ensued, emphasizing the capitalization of "Civil Service" in Section 1 and 4 of Article
XII of the Constitution versus the use of lowercase in Section 670 of the Revised
Administrative Code, suggesting protection exclusively for those in the classified
service in the mentioned constitutional sections.
Issue
W/N the use of capital in the words "Civil Service" in the Constitution and the use of
small letters for the "civil service" in the Revised Administrative code indicates that
the protection only pertains to the classified service.
Held
No. Capital "C" and "S" in the words "Civil Service" were used in the Constitution to
indicate the group. No capitals are used in similar provisions of the Code to indicate
the system. There is no difference between the use of capitals in the former and of
small letters in the latter. As such, there is no reason for excluding persons in the
unclassified service from the benefits extended to those belonging to the classified
service. Both are expressly declared to belong to the Civil. Hence, the same rights and
privileges should be accorded to both. Persons in the unclassified service are so
designated because the nature of their work and qualifications are not subject to
classification, which is not true of those appointed to the classified service. This cannot
be a valid reason for denying privileges to the former that are granted the latter.

Traders Insurance vs Golangco

GR No. L-6442
Facts
Golangco held an insurance policy with Traders and, before its issuance, transparently
disclosed his non-ownership interest in the insured premises. When the building was
destroyed in a fire, Golangco sought insurance proceeds, but Traders denied liability,
asserting he lacked insurable interest as a non-owner. Golangco obtained a favorable
judgment from the First Instance Court of Manila, upheld by the Court of Appeals.
Traders filed a writ of certiorari, alleging two errors by the Court of Appeals: firstly, in

50
not providing a complete factual conclusion on all raised issues as required by Law
No. 296's Article 33, and secondly, in failing to make findings of fact on the
application of the rule of oral evidence and Exhibits 10-H and 10-I. Apparently, the
Traders wants this Court to amend the Court of Appeal's findings of fact on Exhibits
10-H and 10-I. With that the appellant cited the law which reads as follows "Every
decision of the Court of Appeals shall contain complete findings of fact on all issues
properly raised before it." But in Spanish it says like "Every decision of the Court of
Appeals will contain a complete account of the facts of all the issues that arise before
Issue
W/N CA is obligated to consider all the errors indicated in the list of errors that arise
during the course of argument.
Held
No. The contention arises from the inexactness of the Spanish translation. The Spanish
version suggests that the decision of the Court of Appeals should encompass no more
than a "complete account of the facts" related to the raised issues. However, the
English version, specifying "complete findings of fact," implies a deeper examination
and consideration of contradictory evidence. Article 33 of the law, referring to issues
"properly raised," emphasizes the necessity of raising questions in the appropriate
context and time. The court clarifies that not all issues need to be addressed unless
they are duly and properly raised in the statement of errors. Issues not specified in the
list of errors are considered not properly raised, and the Court of Appeals is not
obligated to resolve them.

Manila Lodge No. 761 vs CA

GR No. L-41001
Facts
Act No. 1306, enacted by the Philippine Commission, granted authorization to the City
of Manila for the reclamation of a section of Manila Bay, earmarked for the Luneta
extension. The act explicitly stated that the reclaimed area would be owned by the City
of Manila, granting authority to allocate a portion for a hotel site and allowing either
leasing or selling. Subsequently, the City of Manila conveyed part of the reclaimed
land to Manila Lodge. Later, Manila Lodge sold the land, along with its improvements,

51
to Tarlac Development Corporation (TDC). The City of Manila sought to repurchase
the reclaimed portion, initiating legal proceedings that resulted in a ruling favoring the
city. TDC, dissatisfied with the interpretation of Act No. 1360 and its amendment by
Act No. 1657 by the Court of Appeals, filed a petition for review on certiorari.
Issue
Whether or not the subject property was public dominion.
Held
Yes. The court deemed it essential to scrutinize all the provisions of Act No. 1360, as
amended, to discern the legislative intent. The grant of the reclaimed land to the City
of Manila, as per Act No. 1360, is characterized as a "public" grant. Such grants are
subject to strict construction against the grantee due to being a gratuitous donation of
public resources, potentially providing an undue advantage to the recipient. In this
case, the reclaimed area would be filled at the expense of the Insular Government,
incurring no cost for the City of Manila. Consequently, the wording of the statute
should be narrowly interpreted, excluding elements that, if included, might undermine
the legislative policy. Thus, the property was considered patrimonial property of the
City of Manila.

Automotive Parts vs Lingad

GR No. L-26406
Facts
Seeking to avoid raising their monthly salaries from 152 pesos to 180 pesos per
employee, Automotive Parts and Equipment Co. Inc., the petitioner, contended that
Section 19 of RA 602 (Original Minimum Wage Law) restricting reductions in wages
or supplements only applied to businesses established before the law's enactment in
1951. As the petitioner commenced operations in 1961, they asserted exemption from

52
RA 602. On April 21, 1965, the respondents, including the Secretary of Labor, Jose B.
Lingad, interpreted RA 4180 (the new Minimum Wage Law/amendatory act),
mandating the petitioner to comply with the minimum wage of 180.00 pesos. The
petitioner argued that RA 4180, amending RA 602, solely applied to businesses
predating the old law. The lower court rejected this, citing the re-enactment of
consistent provisions and Article 1702 of the Civil Code favoring laborer safety and
decent living. The new law required employers to pay employees 6.00 pesos per day,
totaling 180.00 pesos monthly.
Issue
W/N the literal interpretation of petitioner is valid
Held
No. The Congress's intent in enacting minimum wage laws is to protect laborers'
minimum wages. The petitioner's literal interpretation, claiming exemption due to
commencing operations after the law's enactment, is deemed absurd and contrary to
the legislative purpose. The court rejects the petitioner's reliance on the word "now" in
Section 19, emphasizing that such an interpretation would render the safeguard against
evading the law ineffective. The court underscores the constitutional mandate to
protect labor and achieve legislative goals, emphasizing that courts should avoid
interpreting words in a manner leading to unreasonable or absurd consequences. The
ruling cites established legal principles, including the rejection of literal interpretations
that result in injustice or absurdity.

Nilo vs CA
GR No. 34586
Facts
The petitions involve the challenge to the effectivity of Republic Act No. 6839,
amending Section 36(1) of Republic Act No. 3844, which permits a landowner to eject
an agricultural lessee based on the owner's intent to personally cultivate the land. In the
first case (GR No. L-34586), the landowner, Almario Gatchalian, filed an ejectment
suit against the agricultural share-tenant, Hospicio Nilo, citing personal cultivation as

53
grounds. Nilo argued that the suit was retaliatory for choosing the leasehold system.
The courts ruled in favor of Gatchalian, stating that Republic Act No. 6389,
eliminating personal cultivation as grounds for ejectment, has no retroactive
application. In the second case (GR No. L-36625), landowner Fortunato Castro
appealed to the Court of Appeals, contesting the dismissal of his complaint to eject
tenant Juan Castro based on personal cultivation. The challenge questioned the
constitutionality of Republic Act No. 6389, which amended the relevant section. The
Court of Agrarian Relations dismissed the complaint after the enactment of Republic
Act No. 6389, emphasizing the elimination of personal cultivation as a ground for
ejectment.
Issue
W/N the amendment in R.A. 6389 should be given retroactive effect to cover cases
that were filed during the effectivity of the repealed provision
Held
No. The Republic Act No. 6389, amending Section 36(1) of RA No. 3844, does not
have a retroactive effect. The Civil Code provides that the laws shall not have a
retroactive effect unless expressly provided. The general rule is that statutes do not
apply retroactively unless otherwise specified. While acknowledging Republic Act No.
6389 as social legislation, the court underscores that social justice is not exclusive to
tenants and extends to small landowners. The legislators' intent in allowing "personal
cultivation" as grounds for ejectment was to encourage landowners to personally
cultivate their lands. However, this provision was misused, leading to the amendatory
law. Despite the unfortunate consequences, the court emphasizes the importance of
preventing injustice to small landowners with genuine intentions to cultivate their
lands.

Escribano vs Avila
GR No. 30375
Facts
Governor-elect Salipada K. Pendatun lodged a libel complaint against Mayor Jose
Escribano of Tacurong, Cotabato (now Sultan Kudarat) on September 25, 1968. The
complaint, affirmed before Judge David P. Avila and supported by Acting Governor

54
Simeon Datumanong's affidavit, triggered a challenge to Judge Avila's authority for
the preliminary investigation. In rulings dated March 5, 20, and 27, 1969, Judge Avila
asserted his competence for the preliminary investigation, citing article 360 of the
Revised Penal Code inserted by Republic Act No. 4363. This article designates
provincial or city fiscals or municipal courts for the preliminary investigation of
written defamations, a power contested by Mayor Escribano.
Issue
W/N the Court of First Instance of Cotabato is invested with authority to conduct the
preliminary investigation of the crime of libel committed by means of radio at
Cotabato City or whether that power is lodged exclusively in the city attorney of that
city
Held
The court ruled that the Court of First Instance has the authority to conduct
preliminary investigations for libel cases. It argues that legislative intent, considering
the mischief intended to be addressed, supports this authority. While article 360 of the
Revised Penal Code specifies other bodies for preliminary investigations, the absence
of the Court of First Instance in the amendment doesn't exclude it. The ruling rejects
the application of the maxim inclusio unius est exclusio alterius, stating that it is not
conclusive and can be ignored when circumstances indicate non-exclusivity. The court
underscores the importance of interpreting laws based on their purpose and giving
them a reasonable and liberal construction.

Litex Employees Association vs Eduvala

GR No. 41106
Facts
The petitioner labor union seeks to nullify an Order issued by respondent George A.
Eduvala, the then Officer-in-Charge of the Bureau of Labor Relations. This Order

55
mandates a referendum election among members of the Litex Employees Association,
the petitioner union, to determine their affiliation with the Federation of Free Workers.
The petitioner contends that such a referendum lacks statutory authorization, citing
Article 226 of the present Labor Code, which grants exclusive authority to the Bureau
of Labor Relations and regional Labor Relations Divisions to address inter-union and
intra-union conflicts. These encompass disputes and grievances related to labor-
management relations, excluding matters arising from collective bargaining agreement
implementation or interpretation, which are subject to grievance procedures and
voluntary arbitration.
Issue
W/N the wording of Article 226 sustains authority
Held
The Court asserted that Article 226 of the New Labor Code should not be narrowly
interpreted to limit the authority granted to the Secretary of Labor and Department
officials. The court emphasized that, especially in promoting social and economic
rights, the active participation in implementing outlined objectives is entrusted to the
executive department. The ruling rejected a misreading of the provision, emphasizing
the flexibility of words in statutory interpretation. Quoting Holmes, the court
highlighted that the general purpose holds more significance than strict adherence to
grammar or formal logic. Holmes warned against courts erring by rigidly sticking to
the literal words of a law when they imply a policy that transcends them. Ultimately,
the court underscored the importance of fulfilling the intended purpose of the code or
statute without frustration.

Regalado vs Yulo
GR No. L-42935
Facts
This case stems from a quo warranto proceeding aimed at determining the rightful
holder of the position of Justice of the Peace of Malinao, Albay, between petitioner

56
Felipe Regalado and respondent Esteban T. Villar. Felipe Regalado assumed the office
of Justice of the Peace of Malinao, Albay, on April 12, 1906. However, on September
13, 1934, Regalado reached the age of 65. Consequently, following instructions from
the Secretary of Justice, the Judge of First Instance of Albay designated Esteban T.
Villar as the new Justice of the Peace of Malinao, Albay. Regalado, under protest,
relinquished the office to Villar.
Issue
W/N under the provisions of section 203 of the Administrative Code, as amended by
the Act No. 3899, the Justices and auxiliary justices appointed prior to the approval of
the Act No. 3899 who reached the age of 65 yrs after said Act took effect shall cease to
hold office upon reaching the age of 65 yrs.
Held
No. The court rejects the proposition because justices appointed prior to the approval
of the act and reaching the age of 65 on September 13, 1934—after the act's approval
on November 16, 1931—are not impacted by the said act. The law mandates cessation
of office on January 1, 1933, does not apply retroactively to justices in this scenario.
The legislative intent is deduced from the language used in construction, and if such
intent is not explicitly expressed, courts cannot speculate or supply meanings beyond
the law's wording through interpretation.

Central Azucarera vs. CA

GR No. L-7731
Facts
The case involves Central Azucarera Don Pedro (Sugar Central), a sugar manufacturer
seeking a refund of special excise tax collected on foreign exchange used for importing

57
Hessian cloth. This cloth was transformed into bags for packing centrifugal sugar
exported to the United States. Despite quoting Section 3 of Republic Act No. 601,
which allowed a refund under certain conditions, the Central Bank denied the refund.
Sugar Central, dissatisfied with this decision, filed a lawsuit in the CFI Manila, aiming
to recover or compel the Central Bank to refund the excise tax paid on the cloth
importations. The contested provision required manufacturers to meet specific criteria
before claiming a refund, emphasizing the actual use of imported items in the
manufacturing process and the subsequent exportation of the local products. The
appellant argued that the law, enacted during the importations, aimed to generate
revenue or preserve and protect dollar reserves, forming the basis of their petition.
Issue
W/N under the provisions of Section 3, Republic Act No. 601, the Hessian (Fiji) cloth,
upon which a special excise tax was assessed and imposed, qualifies when converted
into bags.
Held
Yes. The Supreme Court clarified that the intent of Congress or the purpose of the law
doesn't decide the case when the law itself provides an exception to the general rule on
special excise tax. The ruling emphasized that the term "forming thereof" doesn't
imply the mechanical, physical, or chemical merging of the imported article into the
local product, leading to a loss of identity. Instead, it signifies the necessity of the
imported article in facilitating the export of the locally manufactured product. For
instance, bags made of any fiber, containing centrifugal sugar, are considered part of
the locally manufactured sugar when they play a crucial role in preparing the sugar for
export abroad.

Ramirez vs CA
GR No. 93833
Facts
Petitioner Socorro Ramirez initiated a civil case in the RTC, claiming that private
respondent Ester Garcia insulted and humiliated her in an offensive manner during a

58
confrontation in the office, contrary to morals, good customs, and public policy. To
substantiate her case, the petitioner presented a verbatim transcript of the event and
sought moral damages. In response, the private respondent filed a criminal case,
asserting a violation of the Anti-Wiretapping Law, citing the secret recording of the
confrontation as the basis for the charge.
Issue
W/N the act of recording through a tape constitutes an offense
Held
Yes. The court held that the language of the law, Republic Act No. 4200, is clear and
unambiguous, making it illegal for any person not authorized by all parties to secretly
record private communications using a tape recorder. The statute does not distinguish
whether the party being penalized must be different from those involved in the
communication, emphasizing its intent to penalize any unauthorized person with the
use of the qualifier "any." The content of the conversations is deemed irrelevant to a
violation, and the mere act of making a secret recording suffices to constitute an
offense under the law. The petitioner's argument that "private communication" does
not encompass "private conversations" was rejected, as the ordinary meaning of the
term "communication" includes both verbal and non-verbal exchanges of meanings or
thoughts, as exemplified in the emotionally charged exchange between the petitioner
and respondent in the latter's office.

Celestial Nickle Mining vs Microasia

GR No. 169080
Facts
Macroasia Corporation's mining lease contracts, including Mining Lease Contract V-
1050, were subject to cancellation petitions by Celestial and Blue Ridge. The Panel of

59
Arbitrators (POA) granted Celestial's petition, affirming the exclusive authority of the
DENR Secretary to cancel mining agreements. Blue Ridge's petition, however, was
granted by the CA Special 10th Division, emphasizing that the power to resolve
mining disputes inherently includes the authority to cancel mining agreements,
challenging the MAB's vacated decision. The CA affirmed the DENR Secretary's
exclusive authority, while Blue Ridge argued that the POA has jurisdiction over the
cancellation of mining lease agreements.
Issue
W/N the Secretary of DENR has control over the cancellation of mining contracts and
privileges
Held
Yes. It is only the Secretary of the DENR who has jurisdiction to cancel mining
contracts and privileges. It is firmly established that, in interpreting an ambiguous
provision of law, the history of its enactment can serve as an extrinsic aid to discern its
meaning. The history includes prior laws on the same subject matter, and a review of
legislative history is crucial for understanding the legislative purpose or intent. It is
reasonable to assume that new legislation continues or furthers existing legislative
policy. Therefore, we conclude that, considering the implied power to terminate
mining contracts under earlier laws like PD 463, EO 211, and EO 279, RA 7942
should be interpreted as a continuation of the legislative intent to authorize the DENR
Secretary to cancel mineral agreements for violations of their terms and conditions.

Basiana vs Luna
GR No. 34135
Facts
The petitioners, formerly protestants, argue that the 183 mining claims in question are
located in rows or columns, with the mother claim tied to a cliff and the remaining

60
claims tied to the initial post No. 1 of adjoining or adjacent claims. They contend that
the initial post No. 1 of these adjacent claims is a permanent and prominent object,
qualifying as a valid tie point under Section 47 of the Mining Act. The petitioners
assert that the use of the word "may" in the second paragraph of Section 47 implies
that the enumeration of tie points is not exclusive, allowing for other permanent and
prominent objects as tie points. They further argue that Sections 40 and 43 of the
Mining Act, along with Section 42, make the initial post No. 1 of a staked claim
permanent and prominent, meeting the criteria for a valid tie point.
Issue
W/N petitioner’s mining claim is valid in view of the non-exclusivity of tie point under
Section 47 of the Mining Act.
Held
No. The court held that the enumeration of tie points for locating a mine is exclusive as
provided in Section 47 of the Mining Law. The use of the term "may" in the provision
doesn't imply non-exclusiveness but rather indicates that any one of the enumerated
permanent and prominent objects can be used as a tie point. The amendment
introduced by Republic Act No. 4388 made the enumeration mandatory to eliminate
claim jumpers and minimize overlapping of claims. The last sentence of Section 47, as
amended, emphasizes that a declaration of location without a tie point as described in
the enumeration is null and void. The ruling clarifies that the term "location
monument" in the provision refers to government-established monuments, not posts
placed by mining claim locators, supporting the exclusive nature of the enumerated tie
points.

Arenas vs City of San Carlos

GR No. L-34024
Facts

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City Judge Isidro Arenas of San Carlos City claims a salary differential of P9,500
under Republic Act No. 5967, which sets a basic annual salary for city judges. Despite
his monthly salary being P500 below the prescribed amount, the city government,
citing financial difficulties, refused to pay the differential. The dispute centers on the
interpretation of Section 7, with Arenas arguing that the last proviso, regarding the
salary in relation to the city mayor, should not override the main provision raising city
judges' salaries. He contends that legislative intent supports prioritizing the salary
increase for city judges.
Issue
W/N the city government should pay the petitioner the salary of P18,000.00 fixed by
to RA 5967 despite the proviso stated therein
Held
No. Contrary to what the petitioner contends, the intention of Congress in enacting
Republic Act No. 5967 was that the salary of a city judge should not be higher than the
salary of the city mayor. The saving clause "Provided, however, That the salary of a
city judge shall be at least P100.00 per month less than that of the city mayor"
qualifies the earlier provision which fixes the salary of city judges for second and third
class-cities at P18,000.00 per annum. Since the City mayor of San Carlos City
(Pangasinan) was receiving an annual salary of P13,200.00, the respondents cannot be
compelled to provide for an annual salary of P18,000.00 for the petitioner as city
judge. The primary purpose of a proviso is to limit the general language of a statute.
When there is irreconcilable repugnancy between the proviso and the other body of the
statute the former is given precedence over the latter on the ground that it is the latest
expression of the intent of the legislature.

Escalante vs Santos
GR No. 36828
Facts

62
Arturo V. Escalante, currently in Bilibid prison, initiated this habeas corpus
proceeding. On November 14, 1928, he was convicted of estafa, receiving a sentence
of two years, eleven months, and eleven days of presidio correccional, along with a
restitution order of P4,836.53. The penalty imposed was the minimum within the
prescribed range under the Penal Code, specifically article 534, paragraph No. 3, due
to the amount involved exceeding 6,250 pesetas. Having entered Bilibid on January
17, 1929, the petitioner has served over three years of imprisonment. Estafa involving
an amount not exceeding P6,000 is now penalized under the Revised Penal Code,
effective since the beginning of the year, with a punishment ranging from arresto
mayor to prision correctional. The Attorney-General recommends the petitioner's
release under the provisions of article 22 of the new Penal Code.
Issue
W/N the petitioner can be set to liberty?
Held
Yes. The Supreme Court ruled in favor of the accused, granting the petition for Habeas
Corpus based on Article 22 of the Revised Penal Code. This article states that penal
laws shall have a retroactive effect to favor the person guilty of a felony, provided they
are not a habitual criminal. Applying the law in force at the time of the petitioner's
conviction, Article 315, paragraph 3, of the Revised Penal Code, the court deemed it
more favorable to the accused. As the petitioner had already served the penalty under
the previous law, he was ordered to be set at liberty immediately. The court
emphasized the intention of the law to give retroactive effect to penal laws favorable to
the accused, as evidenced by interpretations from members involved in drafting the
Revised Penal Code. The broad term "penal laws" encompasses all laws of a penal
nature

Salaysay vs. Castro

GR No. L-9669

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Facts
Engracio E. Santos was the duly elected Municipal Mayor of San Juan del Monte,
Rizal, with Nicanor G. Salaysay serving as the Vice-Mayor. In September 1955,
Santos was under suspension due to administrative charges, leading Salaysay to act as
Mayor in accordance with the Revised Administrative Code. While serving as Mayor,
Salaysay filed his certificate of candidacy for the same office. Respondent Provincial
Governor Wenceslao Pascual informed Salaysay that, due to his candidacy filing, he
automatically ceased to be Vice-Mayor. Pascual appointed Sto. Domingo as the acting
Vice-Mayor and directed him to assume the office of Mayor during Santos'
suspension. Salaysay refused, arguing that his case did not fall under Section 27 of the
Election Code, as he was holding the office of Mayor when he filed his candidacy.
Issue
W/N a Vice Mayor acting as Mayor may be regarded as actually holding the office of
the Mayor
Held
No. The court emphasized that the general rule is that government officials running for
office must resign, and the authority to retain one's office while running is an
exception. Statutory construction dictates that exceptions or provisos must be strictly
construed to ascertain legislative intent. While Nicanor G. Salaysay, as Vice-Mayor,
was discharging the duties of the Mayor, the court ruled that he cannot legitimately be
considered as actually holding the office of Mayor. The court concluded that a Vice-
Mayor acting as Mayor does not "actually hold the office" of Mayor within the
meaning of the relevant statute. Consequently, a Vice-Mayor filing a candidacy for
Mayor, even while acting in that capacity, is considered resigned from the office of
Vice-Mayor, and having ceased to be Vice-Mayor, loses the right to act as Mayor
automatically.

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Commission of Customs vs CTS
GR No. 48886-88
Facts
Iligan Bay Express Corporation constructed and maintains berthing facilities at
Kiwalan, Iligan City, solely at its expense. Several foreign-trade vessels, including MS
"Chozan Maru," MS "Samuel S," MS "Ero," MS "Messinia," MS "Pavel Rybin," MS
"Caledonia," and MS "Leonidas," used these facilities on various dates. The Collector
of Customs assessed berthing fees on these vessels, which were paid under protest by
Litonjua Shipping Company Granexport Corporation, representing the vessels. The
fees amounted to P2,551.00, P8,000.00, P5,000.00, P5,000.00, P4,000.00, P7,000.00,
and P9,000.00 on different dates. Litonjua Shipping Company Granexport Corporation
sought a refund by filing cases before the Bureau of Customs, but the protest was
denied by the Collector of Customs in Iligan City. The private respondent then
resorted to the CA which revered the decision of the Bureau of Customs. The
petitioner asserts that the government has the power to levy and collect berthing fees,
whether a vessel docks at a private pier or a national port. In contrast, the private
respondent contends that the government's authority to impose berthing fees is
restricted to national ports exclusively
Issue
Whether or not a vessel engaged in foreign trade, berthing at a privately owned wharf
or pier, is obligated to pay the berthing charge under Section 2901 of the Tariff and
Customs Code, as amended by Presidential Decree No. 34.
Held
No. The Supreme Court ruled that under Section 2901 of the Tariff and Customs Code,
as amended by Presidential Decree No. 34, only vessels berthing at national ports are
liable for berthing fees. The insertion of the word "national" in the amendment
indicates a legislative intent to change the meaning of the provision, excluding
privately owned wharves or piers. Vessels berthing at municipal ports, like the Port of
Kiwalan, are not subject to berthing charges, and the government must refund the fees
collected from private respondent Iligan Express Corporation. The ruling emphasizes
the importance of strict construction in statutory interpretation, adhering to the
principle of expressio unius est exclusio alterius.

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Gloria vs CA
GR No. 131012
Facts
During the teachers' strikes in September and October 1990, public school teachers,
the private respondents, did not report for work, leading to administrative charges and
preventive suspension. The investigation concluded within the 90-day suspension,
resulting in guilty findings for the respondents, with varying penalties. Margallo's
appeal to the Merit Systems and Protection Board (MPSB) led to a six-month
suspension, while the other respondents faced dismissal and a reprimand. The Civil
Service Commission (CSC) affirmed Margallo's penalty but reduced the others to a
reprimand, ordering their reinstatement. Upon appeal to the Court of Appeals (CA),
the decision was affirmed, with the CA additionally ruling that respondents were
entitled to salary payment during their suspension beyond the initial 90 days. Secretary
Gloria moved for reconsideration of the salary payment ruling, but the CA denied this
motion.
Issue
W/N an employee is entitled to the payment of salaries during the period of
suspension?
Held
Yes. The Court of Appeals ruled that the Department of Education, Culture, and Sports
(DECS) should pay private respondents their salaries, allowances, and benefits beyond
the initial 90-day preventive suspension, but only for the period of suspension pending
appeal if they are eventually found innocent. The Court disagreed with the
government's assertion that employees preventively suspended pending investigation
are not entitled to compensation if exonerated. The rule of statutory construction
regarding the amendment by deletion of certain words or phrases in a statute indicates
that the legislature intended to change the meaning of the statute, for the presumption
is that the legislature would not have made the deletion had the intention been not in
effect a change in its meaning.

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Buenaseda vs Flavier
GR No. 106719
Facts
The Private Respondents initiated an administrative complaint against the Petitioner,
accusing them of violating the Anti-Graft and Corrupt Practices Act. In response, the
Ombudsman issued an order for the preventive suspension of the Petitioners, who held
positions at the national center for mental health. The Respondent argued that this
preventive suspension, governed by Sec. 24 of RA 6770, aligns with the provisions of
Sec. 13(8) of Art. 9 in the 1987 Constitution. Conversely, the Petitioner asserts that the
Ombudsman can only recommend preventive suspension to the Heads of Departments
and other agencies in cases of administrative investigations conducted by his office.
The petition, filed under Rule 65 of the Revised Rules of Court, aims to invalidate the
Ombudsman's order for the preventive suspension of the petitioners, including Dr.
Brigida S. Buenaseda et al. The Solicitor General, in his comment, emphasized that the
Ombudsman's authority is limited to recommending suspension, lacking direct power
to suspend. Furthermore, he noted that even if the Ombudsman has such power,
specific conditions mandated by law must be met, which, according to him, are absent
in the present case.
Issue
W/N the Ombudsman has the power to suspend government officials and employees
working in offices other than the Office of the Ombudsman, pending the investigation
of the administrative complaints filed against said officials and employees.
Held
Yes. The Ombudsman has the power to suspend government officials and employees
not specifically under their Office in administrative complaints. The court held that
when the Constitution granted the Ombudsman the authority "to recommend the
suspension" of public officials or employees under Section 13(3), Article IX, the term
"suspension" was understood as a punitive measure. All the terms linked to
"suspension" in the provision pertained to penalties in administrative cases, such as
removal, demotion, fine, and censure. Following the rule of noscitur a sociis, the word
"suspension" should be interpreted in the same sense as the other associated terms.

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Section 24 of R.A. No. 6770, providing the Ombudsman the power to impose
preventive suspension on public officials and employees facing administrative charges,
serves as a procedural tool aiding in the investigation of these charges.
Munoz Co vs Hord
GR No. 4832
Facts
This is an appeal from the Court of First Instance of Manila, where the plaintiff
company seeks the recovery of money paid under protest to the Collector of Internal
Revenue. The payments were made based on sections 139 and 140 of Act No. 1189,
relating to internal-revenue taxes. The plaintiff company contends that goods sold for
exportation should not be considered "goods sold for domestic consumption in the
Philippine Islands." The dispute centers on whether a tax of one-third of 1 per cent on
the value of exported products is justified under the law. The defendant argues that the
taxes imposed are occupation taxes, not directly on goods sold, and asserts that all
sales within the Philippine Islands, regardless of subsequent export, are subject to
taxation unless exempt under section 142.
Issue
W/N the meaning of the phrase “goods sold for domestic consumption” under Sections
139 and 140 of Act No. 1189 is limited
Held
No. The court ruled that the phrase "goods sold for domestic consumption" in sections
139 and 140 of Act No. 1189 should be interpreted broadly to include goods used for
commercial purposes within the Philippine Islands. The appellant argued that the tax
should only apply to goods that are ultimately consumed within the country, excluding
those intended for export. However, the court rejected this narrow interpretation,
stating that the legislative intent was to tax all goods sold for use in commerce within
the Philippines. The court emphasized that revenue laws, unlike penal laws, should be
construed liberally in favor of the government and the public welfare. It pointed out
that the purpose of Act No. 1189 was to provide revenue for the support of the
government through internal taxation. Additionally, the court highlighted that the
amendment to the statute, removing the words "for domestic consumption," did not
alter the legislative intent but was done to clarify and simplify the language. The court
rejected the argument that this amendment reflected a change in the legislative
purpose.

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Greenfield vs Meer
GR No. 156
Facts
The plaintiff, engaged in the embroidery business and trading mining stocks, declared
a net loss of P67,307.80 from stock transactions in the 1939 income tax return. The
defendant disallowed this deduction, asserting that losses from the sale of mining
stocks, considered capital assets, should be limited to the extent of gains. The
defendant assessed the income tax at P13,771.06 without deducting the personal and
additional exemptions of P3,500 to which the plaintiff was entitled. The plaintiff
objected, claiming a refund of P9,008.14, emphasizing the dispute over the defendant's
failure to deduct exemptions against the entire net income.
Issue
W/N the personal and additional exemptions granted by section 23 of the current law
be considered as a credit against the net income, or is it the tax on these exemptions
that should be deducted from the tax on the total net income?
Held
The ruling emphasizes that the omission of the phrase "in the nature of a deduction" in
the new law does not alter the principle that personal and additional exemptions are to
be deducted from the net income before determining the tax. The court holds that the
change in phraseology does not indicate an intention to change the construction of the
old law. The history of the statute and the comparison with the proposed "Wisconsin
Plan" show that there was no substantial change intended. The court also notes that our
Income Tax Law is patterned after U.S. Revenue Laws, and the application of personal
exemptions aligns with the U.S. practice of considering them as deductions from net
income. Where the statute has been enacted which is susceptible of several
interpretations there is no better means for ascertaining the will and intentions of the
legislature than that which is afforded by the history of the statute.

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Carolina Industries vs CMS Stocks
GR No. 46908
Facts
Carolina Industries Inc. filed a case against CMS Stock Brokerage Inc., accusing the
defendant, engaged in buying and selling stocks, of making stock purchases on behalf
of the plaintiff despite the plaintiff's account being undermargin and exceeding the
50% ceiling mandated by Section a.1 of the Securities Act.
Issue
W/N the defendant’s excessive extension of credit in favor of the plaintiff violates the
Security Act
Held
Yes. The Supreme Court typically aligns with American legal interpretations for laws
adopted from the United States, such as securities regulations. Decisions from U.S.
courts interpreting similar laws carry significant weight. If a statute is borrowed from
another jurisdiction and has been previously construed by the courts there, it is
assumed that the statute comes with the given construction. It is established that if a
broker violates the Securities Act or related regulations by extending credit to induce a
customer to purchase securities, the customer can recover any resulting losses. This
right applies, as the legislation considers the customer incapable of self-protection. The
protection afforded by the law extends to both individuals and corporations,
emphasizing safeguarding investors, especially those deemed innocent.

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Republic vs Meralco
GR No. 141314
Facts
MERALCO sought a rate increase, and after a provisional approval, an audit was
conducted. The Commission on Audit recommended not considering MERALCO's
income taxes as operating expenses for rate determination. The Energy Regulatory
Board adopted this recommendation, stating that income taxes should be borne by
stockholders, not passed on to consumers. MERALCO argues that the Public Service
Act in the Philippines, which governs public utilities, was inspired by American laws.
They believe that the practice of deducting income taxes, along with other taxes, from
the total revenues of a public utility is well-established in the United States.
MERALCO contends that since Philippine laws were influenced by American
legislation, the interpretation of American courts regarding the inclusion of income
taxes as a legitimate operating expense should be decisive. They rely on a rule of
statutory construction suggesting that when a law is adopted from a foreign country, it
is presumed to carry the interpretation given to it by the courts of that country before
its adoption in the Philippines.
Issue
W/N the income taxes charge against the operating expense is lawful in view of
American jurisprudence
Held
No. The court rejects the utility company's argument that income tax payments should
be considered a legitimate operating expense. The ruling emphasizes that American
decisions are not automatically binding in the jurisdiction, and laws must be construed
based on the intentions of local lawmakers. The court stresses the need to balance the
interests of public utilities and consumers when regulating rates. Examining the audit
findings, the court determines that even if income tax liability is included as an
operating expense, the utility company still enjoys excess revenue beyond the
authorized rate of return. Therefore, the court concludes that public utilities cannot
overcharge the public, and the inclusion of income taxes as an operating expense is not

71
justified. The ruling underscores the principle that public interest in the jurisdiction
takes precedence over other considerations.

San Miquel Corporation vs Inciong

GR No. 49774
Facts
Cagayan Coca-Cola Free Workers Union filed a complaint on January 3, 1977, against
San Miguel Corporation (Cagayan Coca-Cola Plant), claiming that the company failed
to consider various components, such as sick, vacation, or maternity leaves, premium
rates for work on rest days and special holidays, regular holiday pay, and night
differentials, in calculating the 13th-month pay. The petitioner disputes the inclusion
of payments for sick, vacation, or maternity leaves, night differentials, and premiums
for work on certain days in the computation of the 13th-month pay, contending that
Presidential Decree 851 specifies only the basic salary as the basis.
Issue
W/N PD 851 includes payments for sick, vacation, or maternity leaves, premium of
work done on rest days and special holidays, including pay for regular holidays, and
night differentials should be considered in the computation for the 13-month pay
Held
No. it should not be formed part in the determination of the basic salary. Presidential
Decree 851 and its implementing rules dictate that an employee's 13th-month pay is
calculated based on their basic salary, excluding any compensations or remunerations
considered beyond the scope of the basic pay. Further, the court ruled that benefits
such as cost-of-living allowances, profit-sharing payments, and various other
compensations beyond the basic salary are excluded from the computation of the 13th-
month pay. Supplementary Rules and Regulations Implementing Presidential Decree
851 clearly emphasize the exclusion of earnings and other remunerations, ensuring that
they are not considered part of the basic salary for this purpose. The court found
support for this interpretation in relevant provisions of the Labor Code, emphasizing
that overtime pay and premium for special holidays, considered as additional
compensation, are expressly excluded from the definition of basic salary. Following
the rule of statutory construction of doctrine of verbal legis, when the statute is free
from ambiguity, it must be given its literal meaning and applied without interpretation.

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Maceda vs Macaraeg
GR No. 88291
Facts
Act 120 established the National Power Corporation (NPC) as a public corporation
with a mandate for power development. Subsequent legislations, such as RA 358 and
RA 6395, granted NPC tax exemptions, and PD 380 specified comprehensive
exemptions from all taxes. PD 938 integrated exemptions for Government-Owned and
Controlled Corporations (GOCCs) and allowed restoration by the president or minister
of finance. FIRB resolutions alternately withdrew and restored NPC's tax privileges,
with EO 93 eventually withdrawing the exemptions. NPC sought a refund for taxes
paid on petroleum products, asserting continuous tax exemption. However, the refund
claim was partially granted, and NPC moved for reconsideration, contending for
uninterrupted tax exemption for all petroleum product deliveries.
Issue
W/N NPC is subject to indirect tax exemption under PD 938
Held
Yes. NPC is exempt from all forms of taxes including indirect tax. It is crucial to
underscore that PD 938, particularly designed for NPC's tax exemptions, calls for a
liberal interpretation. The intent, as stated in the preamble, is to enhance the tax-
exempt status of NPC. This approach deviates from strict construction and recognizes
the unique nature of exemptions granted to government entities, emphasizing that
exceptions for state-owned property should not be subjected to the same strictness
applied to exemptions contrary to the state's policy. The prevailing principle here is to
construe the law liberally, aligning with the overarching goal of facilitating NPC's
financial responsibilities and the effective implementation of national policies.

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Vera vs Cuenca
GR No. 33693
Facts
Private respondents, engaged in the production and distribution of filled milk products
in the Philippines, market their items under different brand names. The Commissioner
of Internal Revenue (CIR) instructed them to include a specific inscription on their
products in accordance with Section 169 of the Tax Code. This inscription, regarding
skimmed milk, states that the product is not suitable for infants under one year of age.
Failure to comply within fifteen days would lead to penalties. The Court of First
Instance in Manila ruled in favor of the private respondents, directing the CIR to
permanently refrain from demanding the specified label on their products.
Additionally, the FairTrade Board was ordered to permanently abstain from
investigating the respondents regarding their filled milk products.
Issue
W/N the skimmed milk is included in the scope of Section 169 of the tax code
Held
No, Section 169 of the Tax Code does not extend to filled milk. The specific terms
"skimmed milk" in the heading and "condensed skimmed milk" in the text of the
mentioned section limit the application of the general clause "all milk, in whatever
form, from which the fatty part has been removed totally or in part." This limitation is
guided by the rule of ejusdem generis, where general terms are restricted by specific
terms in the statute. The distinction between skimmed milk and filled milk lies in the
latter having the fatty part replaced with refined coconut oil or corn oil. Therefore,
assuming Section 169 applies to both skimmed and filled milk is neither immediate
nor safe. Moreover, findings indicate that the filled milk products are safe, nutritious,
and suitable for infants, challenging the application of Section 169 and emphasizing
the potential deprivation of property without due process of law.

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Nestle Philippines vs CA
GR No. 86738
Facts
Nestle Philippines, after securing authorization from the Securities and Exchange
Commission (SEC), increased its authorized capital stock from P300 million (divided
into 3 million shares) to P600 million (divided into 6 million shares). Notably, the
corporation's principal stockholders are San Miguel Corporation and Nestle S.A., with
other individual stockholders owning a single share each. Seeking an exemption from
the registration requirement of the Revised Securities Act and associated fees, Nestle
filed a letter with the SEC for the proposed issuance of 344,500 shares to its existing
shareholders, San Miguel Corp. and Nestle S.A. The company argued against double
fee collection for the same transaction, emphasizing the absence of remuneration
related to the additional share issuance. However, the SEC, in response, ruled that fees
were still applicable for the intended share issuance, leading to the initiation of the
current case.
Issue
W/N the issuance of additional shares requires a filing for a petition for exemption of
fees
Held
Yes. The issuance of additional shares requires filing a petition for exemption from
fees. The court examined Sec. 6(A)(4) of the Revised Securities Act, finding
ambiguity in the phrase "issuance of additional capital stock," which could refer to
either increasing the authorized capital stock or issuing already authorized but
unissued stock. Both the SEC and CA resolved the ambiguity by interpreting it as
pertaining to increasing the authorized capital stock. This interpretation was upheld by
the court, emphasizing the deference due to the SEC's construction of statutes, which
allows for effective protection of the investing public. The court rejected Nestle's
interpretation, noting that it might undermine SEC's oversight and protection role for
investors in issuances of previously authorized but unissued capital stock. The ruling

75
prioritizes SEC's ability to ensure transparency and protect investors, emphasizing the
public interest in such regulatory measures.

Phil Sugar Central vs Collector of Customs

GR No. L-27761
Facts
The Philippine Sugar Centrals Agency consistently acted as the representative of the
Ma-ao Sugar Central Company. The plaintiff shipped a total of 5,124,416 gross
kilograms of centrifugal sugar destined for the United States. This sugar was loaded
through a wharf owned and maintained solely by the Ma-ao Sugar Central Company,
leased from the Government of the Philippine Islands. The Insular Collector of
Customs assessed and collected wharfage dues on the sugar at a rate of 2 pesos per
thousand gross kilograms, amounting to a total of 10,248.84 pesos. Despite the
plaintiff paying this amount under protest, the Insular Collector of Customs upheld the
collection. Additionally, both parties agree that Pulupandan, from which the sugar was
exported, was, at the time of shipment and remains, a port of entry of the Philippine
Islands, declared as such by Act No. 3106.
Issue
W/N the Government of the Philippine Islands can legally collect a charge for
wharfage, where it appears that the Government does not own the wharf
Held
Yes. the Government is deemed entitled to have and receive the money in question.
When interpreting the phrase "as a charge for wharfage" in section 14 of the
"Philippine Tariff Act of 1909," the courts should consider the contextual situation and
conditions present at the time of the law's enactment. The primary importance lies in
understanding the purpose and intent behind the law to arrive at a correct interpretation
of its terms. Given the consistent and longstanding construction applied to the words
"as a charge for wharfage" in section 14 of the "Philippine Tariff Act of 1909" and the
actions taken by the Government of the Philippine Islands, these words are construed
to signify the law's intention to establish a fund for the construction, maintenance, and

76
operation of government wharves. Consequently, the law is deemed valid even if the
centrifugal sugar in question was loaded from a private wharf.

Manila Jockey Club vs Games and Amusement

GR No. L-12727
Facts
Republic Act No. 309, as amended by Republic Act No. 983, explicitly allocated 23
Sundays and 16 Saturdays for the Philippine Anti-Tuberculosis Society, the White
Cross, Inc., and the Philippine Charity Sweepstakes Office. Additionally, 12 Saturdays
were reserved for the President's use in support of charitable, relief, or civic purposes.
The remaining racing days were designated for private individuals and entities holding
licenses from the Games and Amusements Board, including the appellants. With the
passage of Republic Act No. 1502, which increased the sweepstakes draw and races to
twelve without specifying the corresponding days, the Games and Amusement Board
decided to decrease the racing days allocated to private individuals and entities by six.
Appellants raised objections, asserting that the increase should be deducted from the
Saturdays reserved for the President or assigned to any other day of the week,
excluding Sunday, Saturday, and legal holidays.
Issue
W/N the petitioner has a vested right to the unreserved Sundays?
Held
No. The appellants lack a vested right to the unreserved racing days, as their
authorization to hold races on those days is contingent on licensing and determination
by the Games and Amusements Board. With the enactment of Republic Act No. 1502,
which increased the sweepstakes draw and races by six without specifying the
corresponding days, the Board had no choice but to accommodate the additional races
from the available racing days not reserved by law. In interpreting a legal document,
particularly a statute, it is insufficient merely to discern the intention or meaning of the
author. The focus extends to determining whether the intention or meaning has been
expressed in a manner that imparts legal effect and validity. The inquiry aims not only

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to understand the author's intent but also to ensure that the language used adequately
conveys that intent. Courts are concerned with the expressed intention in the statute,
and motivations behind its passage are not subject to examination. The legislative act
involves both internal intention and external expression, with the failure of the latter
jeopardizing the former. The legal interpretation rests on the statute's language, not on
the views of individual legislators or committees.

Alexander Howden vs CIR

GR No. 19392
Facts
In 1950, Commonwealth Insurance Co., a Philippine corporation, entered reinsurance
contracts with 32 British insurance companies, facilitated by Alexander Howden &
Co., Ltd., a British corporation not doing business in the Philippines. The contracts
were prepared in England, sent to Manila, and signed by the foreign reinsurers. In
1951, Commonwealth Insurance Co. remitted P798,297.47 as reinsurance premiums to
Alexander Howden & Co., Ltd. The latter declared this amount as gross income for
1951, paid income tax, and later sought a refund based on a Commissioner's ruling
exempting such reinsurance premiums from withholding tax. The Tax Court denied
the claim, prompting an appeal that raised questions about the taxation of premiums
earned through reinsurance contracts involving domestic and foreign entities.
Issue
W/N portions of premiums earned from insurances locally underwritten by a domestic
corporation, ceded to and received by non-resident foreign reinsurance companies,
through a non-resident foreign insurance broker, pursuant to reinsurance contracts
signed by the reinsurers abroad but signed by the domestic corporation in the
Philippines is subject to income tax.
Held
YES. Section 24 of the NIRC subjects to tax a non-resident foreign corporation's
income from sources within the Philippines. Section 24 of the Tax Code does not
require a foreign corporation to be engaged in business in the Philippines in order for
its income from sources within the Philippines to be taxable. It subjects foreign
corporations not doing business in the Philippines to tax for income from sources
within the Philippines. If by source of income is meant the business of the taxpayer,
foreign corporations not engaged in business in the Philippines would be exempt from

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taxation on their income from sources within the Philippines. "Income" refers to the
flow of wealth. Such flow, proceeded from the Philippines. Such income enjoyed the
protection of the Philippine Government. As wealth flowing from within the taxing
jurisdiction of the Philippines and in consideration for protection accorded it by the
Philippines, said income should properly share the burden of maintaining the
government

CIR vs American Express

GR No. 152609
Facts
The respondent, a VAT taxpayer, sought a refund of its 1997 excess input taxes,
asserting Section 110B of the 1997 Tax Code, allowing the refund of input tax related
to capital goods or zero-rated sales. The respondent, a Philippine branch of AMEX
USA, serviced AMEX-Hongkong Branch, managing collections and payments within
the Philippines. Relying on VAT Ruling No. 080-89, the respondent argued that its
services were automatically zero-rated as a VAT-registered entity receiving payment
in acceptable foreign currency. The petitioner contested the refund, claiming a strict
construction against the claimant due to the nature of tax exemption. The CTA ruled in
favor of the respondent, asserting that its services were subject to zero-rate, a decision
affirmed by the CA, which additionally characterized the services as falling outside the
scope of processing, manufacturing, or repackaging goods for foreign businesses.
Issue
W/N AMEX Philippines is entitled to zero rate tax pursuant to the construction of the
Tax Reform Act?
Held
Yes. The court ruled that the respondent is entitled to the refund of excess taxes under
Section 102(b)(2) of the Tax Code. The court emphasized that the language of the
provision is clear and unambiguous, requiring no statutory construction or
interpretation. It held that introducing conditions or limitations where none is provided
for is impermissible, as rewriting the law is within the exclusive purview of Congress.
The court asserted that when the law speaks unequivocally, there is no room for
interpretation; only application is warranted. While the BIR commissioner has
interpretive authority, any new construction must align with the law, and no

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interpretation can alter the clear mandate of the statute. As a result, the petition was
denied, and the previous decision in favor of the respondent was affirmed.

Assoc. Sugar vs Corn of Customs

GR No. L-30391
Facts
The case involves the legality of P904,236.38 wharfage dues collected by the
Commissioner of Customs from five petitioners for exporting sugar from private
wharves. Between 1959 and 1966, the petitioners shipped sugar to the U.S. from
private wharves in Bacolod City and Pulupandan, Negros Occidental. Despite no
government port facilities being used, the Collector of Customs imposed wharfage
dues based on sections 2801 and 2802 of the Tariff and Customs Code. The
petitioners, paying under protest, appealed the Collector's decision to the
Commissioner of Customs and later to the Court of Tax Appeals, which dismissed the
case in 1968. The petitioners argue that wharfage fees should not apply since they used
private wharves without government facilities.
Issue
W/N imposition of wharfage dues is lawful even the sugar was shipped from a private
wharf
Held
Yes. The court's decision underscores that, according to the rule of stare decisis, the
imposition of wharfage dues is lawful even when the shipment is made from a private
wharf. Referring to Section 2801 of the Customs and Tariff Code and relying on the
1927 case of Philippine Sugar Centrals Agency v. Insular Collector of Customs, the
court reaffirms the legality of wharfage dues. The historical context is emphasized,
noting that charges for wharfage were collected on exports since 1901, despite the
absence of government piers or wharves. This precedent is reiterated in subsequent
cases, including Victorias Milling Co Inc. v. Auditor General and Procter and Gamble
PMC v. Commissioner of Customs. The court concludes that this matter is settled, and

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adherence to stare decisis dictates following this established principle in statutory
construction.

Tung Chin Hui vs Rodriguez

GR No. 137571
Facts
The petitioner, a Taiwanese citizen, entered the Philippines in 1998 but was arrested
and faced deportation due to a tampered passport. The trial court granted his habeas
corpus petition, ordering his release. Respondents filed a Notice of Appeal, which
petitioner argued was beyond the 48-hour period under the pre-1997 Rules of Court.
Despite the repeal of this rule, the trial court accepted the appeal. The petitioner
contended that the Notice referred to the wrong decision, but the court denied
reconsideration.
Issue
W/N the 48-hour reglementary period for filing appeals in habeas corpus cases, as
prescribed in Section 18 of Rule 41 of the pre-1997 Rules of Court, remains applicable
despite omission and repeal in the 1997 Revised Rules of Court.
Held
No. It’s a well-settled rule of statutory construction that provision from an old law not
included in its revisions that pertain to the same subject are deemed repealed and no
longer in effect. The omission reflects the rule-making body’s intent, in this instance,
the Supreme Court, to discard provisions not included in the revised statue or code.
Therefore the court rules in favor of the respondents, considering the Notice of Appeal
as timely filed in accordance with the applicable rules.

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