Statutory Construction Notes - Atty.

Carla Bayquen
TYPES OF LAWS

1. PHILIPPINE CONSTITUTION 4. ORDINANCES – General Welfare Clause

● Supreme Law of the land (Constitutional ● Every local government unit shall exercise the
Supremacy) powers expressly granted, those necessarily
● The basic and paramount law to which all other implied there from, as well as powers necessary,
laws must conform and to which all persons appropriate, or incidental for its efficient and
must defer. effective governance, and those which are
● Fundamental and organic law of a nation or essential to the promotion of the general welfare.
state, which establishes the concept, character, ● Local Legislative Power
and organization of its government, as well as ○ Vested in the Sangguniang Panlalawigan
describing the extent of its sovereignty and the for the province, the Sangguniang
manner of its exercise. Panglunsod for the city, and the
Sangguniang Bayan for the municipality
Constitutional Law – Political Law
● Branch of public law that deals with organization 5. IMPLEMENTING RULES AND REGULATIONS
and operation of governmental organs of the ● The reasons given above for the delegation of
State and defines the relations of the state with legislative powers in general are particularly
the inhabitants of its territory. applicable to administrative bodies. With the
proliferation of specialized activities and their
2. STATUTES attendant peculiar problems, the national
● An act of the legislature legislature has found it more and more
● A particular law enacted and established by the necessary to entrust to administrative agencies
will of the legislative department of government, the authority to issue rules to carry out the
expressed with the requisite formalities. general provisions of the statute. This is called
● Legislative Power – According to the 1987 the "power of subordinate legislation."
Constitution, legislative power shall be vested in ● With this power, administrative bodies may
the Congress of the Philippines, which shall implement the broad policies laid down in a
consist of a Senate and a House of statute by "filling in' the details which the
Representatives. Legislative power is the power Congress may not have the opportunity or
to make, alter, and repeal laws. competence to provide.
● Two types of Statutes:
a. Permanent Statute – operation is not PARTS OF A STATUTE
limited in duration but continues until it
is repealed 1. TITLE
b. Temporary Statute – duration is for a ● It is the part of the law that provides the name by
limited period of time fixed in the statute which it is individually known.
(i.e. Emergency Statutes) ● It should only embrace one subject (Article 6,
c. Section 26, Constitution)
3. EXECUTIVE ISSUANCES ● Conflict between Title and Body of a Law – The
● Article VII, Section 1, of the 1987 Constitution title of the bill breathes the spirit of command
vests executive power on the President of the because the Constitution does not exact
Philippines. The President is the Head of State Congress the obligation to read the entire text
and Head of Government, and functions as the during the deliberations.
commander-in-chief of the Armed Forces of the 2. PREAMBLE
Philippines. ● Introductory part of the statute stating the
● Presidential Issuances reason and intent of the law.
○ Executive Orders 3. ENACTING CLAUSE
○ Administrative Orders ● declares its enactment and identifies which
○ Proclamations government body enacted the statute or
○ Memorandum Orders regulation.
○ Memorandum Circulars 4. BODY
○ General or Special Orders

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 Statutory Construction Notes - Atty. Carla Bayquen
● part of the statute which contains the operative
parts, such as its substantive and procedural Cases:
provisions. Body of the statute may include: 1. Antonio v. Miranda, G.R. No. 135869, 22
○ Short Title September 1999
○ Definition of Terms 2. Tatad v. DOE, G.R. No. 124360, 3 December 1997
○ Policy Section - used instead of
preamble sometimes 7. EFFECTIVITY CLAUSE
○ Substantive Provisions - sets forth the ● Part of the statute which announces the date of
rights, powers, privileges and immunities its effectivity. Without the publication
of persons benefited or regulated by the requirement, there would be no basis for the
statute maxim ignoratia legis non excusat to apply.
○ Penal Clause - sets forth the sanctions
that may be imposed against persons for Cases:
violation of the statute. Sanction may be 1. Tañada v. Tuvera, G.R. no. 63915, 24 Apr 1985, 29
civil, administrative or criminal Dec 1986
○ Administrative Section - manner in
which the statute will be implemented, VALIDITY
includes creation of administrative - Presumption of Constitutionality: every Statute
agencies and enumeration of powers is presumed valid and constitutional
and responsibilities - To justify the nullification of the law, there must
be clear and equivocal breach of the
5. REPEALING CLAUSE Constitution, not a doubtful and argumentative
● part of statute which identifies the prior statutes implication
or parts thereof are deemed repealed or - The final authority to declare unconstitutionality
abrogated by reason of the enactment of the new is the Supreme Court sitting en banc (Sec. 4 Par.
statute 2, Art. VIII, Constitution)
● Maybe Expressed or Implied - Presumption of Justice: Article 10 of the Civil
● Two types of Implied repeals: Code: “In case of doubt in the interpretation or
a. Irreconcilable Contradiction - Provision application of laws, it is presumed that the
of the two acts on the same subject lawmaking body intended right and justice to
matter are irreconcilably contradictory, prevail.”
the latter act, to the extent of the conflict,
constitutes an implied repeal of the EFFECT & OPERATION
earlier statute. ● When laws take effect: Laws shall take effect after
b. Substitution - If the latter statute covers fifteen days following the completion of their
the whole subject matter of the earlier publication in the Official Gazette, unless it is
one and is clearly intended to be a otherwise provided. This Code shall take effect one
substitute. year after such publication. (Art. 2, New Civil Code)
● For issuances, rules and regulations, there should be
6. SEPARABILITY CLAUSE a publication30 and filing in the the UP Law Center
● It is the part of the statute which makes the ● For ordinances, Sec. 59 of the Local Government
statute’s parts or provisions severable so that Code shall apply
one part can be invalidated without invalidating
the whole. RELATED LEGAL PRINCIPLES
● General Rule: If a part of statute is invalidated,
the other portions, if separable from the invalid 1. SEPARATION OF POWERS
portion, may stand and be enforced. ● A fundamental principle in our system of
● Exception: If the parts of the statute are so government provided expressly by the
mutually dependent and connected, as Constitution. Wherein the three powers are to be
conditions, considerations, inducements or kept separate and that they are absolutely
compensations for each other, as to warrant a unrestrained and independent of each other.
belief that the legislature intended them as a
whole, the nullity of one part will vitiate the rest. 2. CHECKS AND BALANCES

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 Statutory Construction Notes - Atty. Carla Bayquen
● The Constitution has provided for an elaborate - There is no one solution or formula to
system of checks and balances to secure construction; thus the need to interpret it with
coordination in the working of the three branches due respect to the intention and application of
of the government. the law.

3. HIERARCHY OF LAWS (Art. 7, Civil Code) Cases:

● Laws are repealed only by subsequent ones and 1. Caltex v. Palomar, 18 SCRA 247
their violation or non-observance shall not be
excused by disuse or custom or practice to the
contrary. CHARACTERISTICS
● When the courts declare a law to be inconsistent - An art or process
with the Constitution, the former shall be void - Involves determination of Legislative Intent
and the latter shall govern. - Only necessary when Legislative Intent cannot be
● Administrative or executive acts, orders and readily ascertained
regulations shall be valid only when they are not - Judicial Function
contrary to laws or the Constitution. (Article 7,
NCC). Cases:
1. Alonzo v. IAC, G.R. 72873, 28 May 1987
4. STARE DECISIS (Art.8, Civil Code) 2. Nitafan v. CIR, G.R. No. 78780, 23 July 1987
● Stare Decisis means “to stand by things 3. People v. Concepcion, 44 Phil. 126, 29 November
decided”. 1922
● The Doctrine of Judicial Precedence: it sets a
precedence for future cases with similar PURPOSE OF CONSTRUCTION
circumstances and/or facts from a previous
decision or ruling. ● To ascertain legislative intent
● Judicial decisions applying or interpreting the ● Where there is ambiguity in the language of a statute,
laws or the Constitution shall form a part of the courts employ canons of statutory construction to
legal system of the Philippines. ascertain its true intent and meaning.
● Stare decisis is the doctrine that courts will ● It is a cardinal rule that, in seeking the meaning of the
adhere to precedent in making their decision. law, the first concern of the judge should be to
● It requires the courts to follow the rule discover in its provisions the intent of the lawmaker.
established in a decision of the Supreme Court
(Article 8, NCC — “Judicial decisions applying or CONSTRUCTION VS. INTERPRETATION
interpreting the laws or the Constitution shall
form a part of the legal system of the Construction
Philippines”). ● Extrinsic aids or those extraneous facts and
● Where the court resolved a question merely sub circumstances found outside of the written language
silentio (in silence), its decision does not come of the law
from within the maxim of stare decisis. ● Employed when intent cannot be ascertained by
intrinsic aid or from the plain language of the law
STATUTORY CONSTRUCTION ● Process of drawing warranted conclusions not
always included in direct expressions, or determining
DEFINITION the application of words to facts in litigation
- “Construction is the art or process of discovering
and expounding the meaning and intention of the Interpretation
authors of the law with respect to its application ● Intrinsic aids or those found in the statute itself
to a given case, where that intention is rendered ● Employed when there is ambiguity in the language of
doubtful, among others, by reason of the fact the law
that the given case is not explicitly provided for ● Art of finding the true meaning and sense of any
in the law.” (Caltex v. Palomar) form of the words
- “It is the art of seeking the intention of the
legislature in enacting a statute and applying it to POWER TO CONSTRUE
a given state of facts.” (Justice Martin)

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 Statutory Construction Notes - Atty. Carla Bayquen
Construction is a judicial function. ○ Leave law enforcers unbridled discretion
● The duty and power to interpret or construe a statute in carrying out its provisions
or the Constitution belongs to the judiciary (Sec. 4
Par. 2, Art. VIII. Constitution). 2. Courts may not be influenced by questions of
● The court has the final word as to what the law wisdom
means. It construes laws as it decides cases based ● Courts do not sit to resolve the merit of conflict
on fact and the law involved. theories.
● Laws are interpreted in the context of a peculiar ● Courts do not pass upon questions of wisdom,
factual situation of each case. justice, or expediency of legislation, for it is not
● Circumstances of time, place, event, person and within their province to supervise legislation and
particularly attendant circumstances and actions keep it within the bounds of common sense.
before, during and after the operative fact have taken ● The court merely interprets regardless of
their totality so that justice can be rationally and whether they are wise or salutary.
fairly dispensed.
● Condition sine qua non: Before the court may use its Cases:
power to construe, there must be ambiguity in the 1. Tanada v. Yulo, G.R. No. 43575, 31 May 1935
language of the statute. For where there is no 2. Floresca v. Philex, G.R. No. L-30642, 30 April
ambiguity, there is no room for construction, only for 1985
application.
LIMITATION
Cases:
1. Endencia v. David, G.R. Nos. L-6355-56, 31 The legislature has no power to overrule the
August 1953 interpretation made by the Court.
● The legislature cannot, by law or resolution, modify or
LIMITATION ON THE POWER TO CONSTRUE annul the judicial construction without modifying or
repealing the very statute which has been subject of
● The Court can only construe an applicable law in construction.
controversies which are ripe for judicial resolution. ● Exceptions:
Neither moot nor academic (purpose has become ○ When the Supreme Court reverses itself
stale or where no practical relief can be granted or ○ By amending the Constitution
which can have no practical effect). ○ By enacting a new statute
● Exception: If the issue is “capable of repetition yet
evading review” especially where public interest LEGISLATIVE INTENT
requires its resolutions.
● It is the essence of the law. It is the spirit which gives
TWO LIMITATIONS ON THE POWER OF COURTS TO life to legislative enactment.
CONSTRUE ● The purpose is to ascertain and give effect to the
intent of the law – to determine legislative intent,
1. Courts may not enlarge or restrict statutes either expressly or impliedly, by the language used
● Courts are not authorized to insert into the law and determine the meaning and will of the
what they think should be in it, or to supply what law-making body and discover its true interpretations
the legislature would have supplied if its of the law. (Agpalo)
intention had been called to the omission. ● Primary source of legislative intent is the statute
● They should not construct, revise even the most itself.
arbitrary or unfair action of the legislature, nor ● Purpose: reason why a particular statute was
rewrite the law to conform to what they think enacted
should be the law. ● Meaning: what it comprehends, covers, embraces;
● Neither should the courts construe statutes what it limits and confines
which are perfectly vague for it violates due
process. TYPES OF LEGISLATIVE INTENT
○ Failure to accord persons fair notice of
the conduct to avoid; 1. VERBA LEGIS - Literal Interpretation

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 Statutory Construction Notes - Atty. Carla Bayquen
● Verba legis non est recedendum – “from the court may even depart from the language of a
words of a statute, there should be no departure” statute if to do so will enable it to effectuate
● The Plain Meaning Rule — if the statute is clear, legislative intent and purpose.
plain and free from ambiguity, it must be given its ● If a language is capable of more than one
literal meaning and applied without meaning is to be taken in such sense as to
interpretation. harmonize with the intention and object and
● The duty of the court is limited to inquiring into effectuate the purpose of the enactment.
the legislative intent and, once this is determined, ● The two construction principles should be
to making said intent effective. viewed as complementary. The Courts should
● Where the law speaks in clear and categorical abandon verba legis and apply ratio legis in order
language, there is no room for interpretation. to determine the true intent of the legislature,
There is only room for application. (Cebu only in cases when the statute is ambiguous.
Portland Cement v. Municipality of Naga) ● ninguno non due enriquecerse tortizeramente
● Law cannot be changed under the guise of con dano de otro — When the statute is silent or
interpretation. (Crisologo v. Macadaeg) ambiguous, this is one of those fundamental
● Based on the maxims: solutions that would respond to the vehement
a. Index animi sermo est – speech is the urge of conscience.
index of intention. (There is a
presumption that the words employed by Cases:
legislature in a statute correctly express 1. Alonzo v. IAC, (supra)
its intention and prevent the court from 2. Salvacion v. Central Bank, G.R. No. 94723, 21
construing it differently because the August 1997
legislature members are presumed to 3. People v. Purisima, G.R. No. L-42050-66, 20
know the meaning of the words they November 1978
used and have expressed its intent.) 4. Matabuena v. Cervantes, 38 SCRA 284, 31 March
b. Absoluta sententia expositore non 1971
indiget – to the plain words of a legal
provision, we should make no further 3. WHEN CONSTRUCTION NECESSARY
explanation. ● When there is ambiguity in the words of a
statute, there is no room for construction.
Cases: ● Where the law is free from ambiguity, the court
1. Tanada v. Yulo (supra) may not introduce exceptions or conditions
2. Globe-Mackay Cable and Radio Corporation v. where none is provided.
NLRC and Salazar, G.R. No. 82511, 3 March 1992
3. Saguisag et.al. v. Ochoa, et.al., G.R. No. 212426, Cases:
12 January 2016 1. Del Mar v. PAGCOR, G.R. No. 138298, 29
November 2000
2. RATIO LEGIS – Spirit of the law 2. People v. Nazario, G.R. No. L-44143, 31 August
● Ratio Legis est Anima — “the reason of the law is 1988
the soul of the law” 3. In re Allen, G.R. No. 1455, 29 October 1903
● Ratione cessat lex et cessat lex – “when the
reason of the law ceases, the law ceases” 4. CLERICAL ERROR
● Article 10 NCC: In case of doubt in the ● The court, in order to carry out the obvious intent
interpretation or application of laws, it is of the legislature, may correct clerical errors,
presumed that the lawmaking body intended mistakes or misprints which, if uncorrected, may
right and justice to prevail. render the statute meaningless, empty or
● A statute must be read according to its spirit or nonsensical or would defeat or impair the
intent. What is within the spirit is within the intended operation.
statute, although it is not within its letter.
● A statute must be capable of construction or Cases:
interpretation. The court must use every 1. Lopez & Sons, Inc. v. CTA, G.R. No. L-9274, 1
authorized means to ascertain the intent of the February 1957
statute and give it an intelligible meaning. The

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 Statutory Construction Notes - Atty. Carla Bayquen
PRINCIPLES OF CONSTRUCTION
Penal Laws
GENERAL POLICIES OF CONSTRUCTION ● Those which define crimes, treat of their nature,
a. Plain Meaning Rule and provide for their punishment.
● Where the words of a statute are clear, plain, and ● General Rule: Penal statute shall not be
free from ambiguity, it must be given its literal construed to make the commission of certain
meaning and applied without attempted prohibited acts criminal without regard to the
interpretation. (Regalado v.Yulo) intent of the doer.
● Apply the law when it is clear. ● Maxim: actus non facit reum nisi mens sit rea –
● The elementary rule in statutory construction is the act itself does not make a man guilty unless
that when the words and phrases of the statute his intention were so
are clear and unequivocal, their meaning must be ● Exception: If acts are only mala prohibita and the
determined from the language employed and the ● statutes plainly prohibits an act without implying
statute must be taken to mean exactly what it that it be done knowingly or wilfully.
says. ● Strictly construed against the State and liberally
● Hence, what is not clearly provided in the law in favor of the accused.
cannot be extended to those matters outside its ○ The law is tender in favor of rights of an
scope. (Baranda v.Gustilo) individual; the object is to establish a certain
rule by conformity to which mankind would
b. Dura Lex Sed Lex be safe, and the discretion of the court
● “The law is harsh but it is the law.” limited.
● A statute, being the will of the legislature, should ○ It is not to enable a guilty person to escape
be applied in exactly the way the legislature has punishment through a technicality but to
expressed itself clearly in the law. provide a precise definition of forbidden acts.
● The clear, unambiguous and unequivocal ● Limitations to construction in favor of the
language of statute precludes the court from accused:
construing it and gives no discretion but to apply ○ Not to be construed as to defeat the obvious
the law. (Regalado v. Yulo) purpose of the legislature
● It is the sworn duty of the judge to apply the law ○ Only when the law is ambiguous and there is
without fear or favor, to follow its mandate—not doubt in its meaning
to tamper. The court cannot adopt a policy
different from that of the law. What the law Cases:
grants, the court cannot deny. (Go v. Anti-Chinese 1. Centeno v. Villalon Pornillos, G.R. No. 113092, 1
League) September 1994
2. U.S. v. Go Chico, G.R. No. 4963, 15 September
LAW CONSTRUED AS A WHOLE 1909
● A statute is passed as a whole and not in parts
or sections and is animated by one general Tax Laws
purpose and intent. ● Tax laws should be construed strictly against the
● Consequently each part or section should be state (or, the taxing authority) and liberally in
construed in connection with every other part or favor of the taxpayer.
section and so as to produce a harmonious ● Any doubt or ambiguity arising out of the terms
whole. It is not proper to confine the attention to used in granting that power must be resolved
the one section to be construed. It is always an against the local government unit (LGU).
unsafe way of construing a statute or contract to Inferences, implications, and deductions have no
divide it by a process of etymological dissection, place in the interpretation of the taxing power of
into separate words, and then apply to each, thus the municipal corporation. (Agpalo)
separated from its context, some particular ● Statutes prescribing limitations of the taxing
definition given by lexicographers, and then power of LGUs must be strictly construed
reconstruct the instrument upon the basis of against the national government, and liberally in
these definitions. (Sotto v. Sotto) favor of the LGUs. (Agpalo)

INTERPRETATIONS OF CERTAIN STATUTES

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 Statutory Construction Notes - Atty. Carla Bayquen
● Statutes imposing penalties for non-payment of 2. Provincial Sheriff of Rizal v. CA, et al., G.R. No.
taxes within the required period are liberally L-22606, 12 December 1975
construed and interpreted against the taxpayer.
Law on Adoption
Cases: ● It is a well-settled rule that adoption statutes,
1. Marinduque Iron Mines v. Municipal Council, G.R. being humane and salutary in nature, are to be
No. L-18924, 30 June 1964 liberally construed on account of the child to be
2. NPC v. City of Cabanatuan, G.R. No. 149110, 9 adopted. The welfare of the child must be of
April 2003 paramount consideration.
● The interest of the adopted child should be the
Social Legislation primary and paramount consideration for every
● General Rule: legislations that implement the reasonable intention should be sustained.
social justice and protection-to-labor provisions
of the Constitution are known as general welfare Cases:
legislations. These statutes are construed 1. Duncan v. CFI, G.R. No.L-30576, 10 February
liberally. 1976
● In general welfare legislations, the courts will be
guided by more than just an inquiry into the letter Local Government/Local Autonomy
of the law as against its spirit, and will ultimately ● Any interpretation of the provisions of the Local
resolve any doubt in favor of the persons whom Government Code shall follow these rules:
the law intended to benefit, whether it may be ○ Liberally interpreted in favor of the local
labor laws, tenancy laws, land reform laws, and government unit.
social security laws. ○ With regard to tax ordinance, any tax
● However, while general welfare legislations are ordinance or revenue measure shall be
construed liberally in favor of those intended to construed strictly against the local
be benefited, this principle holds true only when government unit enacting it and in favor of
there is doubt or ambiguity in the law, and not the taxpayer. However in cases of Tax
when the law itself is clear and free from doubt. Exemptions, it shall be construed strictly
against the person claiming it.
Cases: ○ The general welfare provisions in LGC shall
1. International Pharmaceuticals, Inc. v. Secretary, be liberally interpreted to give more powers
G.R. No. 92981, 9 January 1992 to local government units in accelerating
economic development and upgrading the
Rules of Court quality life of the people in the community.
● The Rules of Court shall be liberally construed to
promote their objective of securing a just, Cases:
speedy, and inexpensive disposition of every 1. San Juan v. CSC, G.R. No. 92299, 19 April 1991
action and proceeding.
● Usually relaxed in Criminal cases than in Civil Constitution
ones. ● We look to the language of the document itself in
● Where a rigid application of the rule will result in our search for its meaning. (Verba Legis),
manifest failure or miscarriage of justice, then However, we do not stop there, it is only where
the rule may be relaxed, especially if a party we begin.
successfully shows that the alleged defect in the ● It is assumed that the words where
questioned final and executory judgment is not constitutional provisions are couched express
apparent on its face or from the recitals the objective sought to be attained. They are to
contained therein. (Goldloop Properties Inc vs. be given their ordinary meaning except where
CA) technical terms are employed.
● As the Constitution is not primarily a lawyer’s
Cases: document, it being essential for the rule of law to
1. Office of the Court Administrator v. Garong, A.M. obtain that it should ever be present in the
No. P-99-1311, 15 August 2001 people’s consciousness, its language as much as

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 Statutory Construction Notes - Atty. Carla Bayquen
possible should be understood in the sense they 1. Bagong Bayani v. COMELEC, G.R. No. 147589, 26
have in common use. June 2011
● Next would be Ratio Legis which involves looking 2. Manila Prince Hotel v. GSIS, G.R. No. 122156, 3
at the intent of the framers if the statute’s literal Feb 1997
wording produces injustice, and finally Ut Magis 3. Francisco v. HOR, G.R. No. 160261, 10 November
Valeat Quam Pereat (“let the thing be more valued 2003
than it perishes” – to give effect to the matter 4. de Castro v. JBC, G.R. No. 191002, 17 March
rather than having it fail), where the Constitution 2010
is interpreted as a whole. 5. Chavez v. JBC, G.R. No. 202242, 17 July 2012
6. David v. SET, G.R. No. 221538, 20 September
Cases: 2016

TOPIC CASE SUMMARY STATCON APPLICATION

Separability Antonio v. In a case involving an election protest for The right to appeal is merely a
Cause Miranda, G.R. No. the position of Punong Barangay, the statutory privilege and may be
135869 Supreme Court rules that the period to exercised only in the manner
appeal a decision of a municipal trial court prescribed by, and in accordance
to the Commission on Elections with, the provisions of the law.
(COMELEC) is five days, as provided for in
the COMELEC Rules of Procedure, rather
than ten days as stated in Republic Act
6679 and the Omnibus Election Code.

Separability Tatad v. DOE, RA 8180 was enacted on March 1996 A separability clause states that
Cause G.R. No. 124360 if, for any reason, any section or
The Supreme Court upholds the provision of the statute is held to
constitutionality of the Downstream Oil be unconstitutional or invalid, the
Industry Regulation Act of 1996 but finds other section(s) or provision(s)
that the Executive misapplied the standards of the law shall not be affected
by prematurely deregulating the industry. thereby. It is a legislative
expression of intent that the
nullity of one provision shall not
invalidate the other provisions of
the act. Such a clause is not,
however, controlling, and the
courts may, in spite of it,
invalidate the whole statute
where what is left, after the void
part, is not complete and
workable.

Effectivity Clause Tañada v. Tuvera, In the case of Tañada v. Tuvera, the court ”Unless it is otherwise provided”,
G.R. no. 63915 ruled in favor of the petitioners, affirming refers to the effectivity of laws
the necessity for the publication of and NOT the requirement of
presidential decrees to ensure the people's publication itself which cannot in
right to due process and information on any event be omitted.
matters of public concern.
It is not correct to say that under
the disputed clause publication
may be dispensed with
altogether. The reason is that
such omission would offend due
process insofar as it would deny
the public knowledge of the laws
that are supposed to govern it.

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 Statutory Construction Notes - Atty. Carla Bayquen
TOPIC CASE SUMMARY STATCON APPLICATION

Statutory Caltex v. In 1960, Caltex devised a promotional “Construction is the art or

Construction, Palomar, 18 scheme called the "Caltex Hooded Pump process of discovering and
defined SCRA 247 Contest" to boost patronage for its oil expounding the meaning and
products. The contest required participants intention of the authors of the
to estimate the number of liters a hooded law with respect to its
gas pump at each Caltex station would application to a given case,
dispense over a specified period. where that intention is rendered
doubtful, among others, by
Caltex sought clearance from the postal reason of the fact that the given
authorities to use the mails for publicizing case is not explicitly provided for
the contest, citing sections 1954(a), 1982, in the law.”
and 1983 of the Revised Administrative
Code. The Acting Postmaster General
denied the request, asserting that the
contest violated anti-lottery provisions

The Supreme Court ruled in fa*vor of Caltex

(Philippines) Inc. in a petition for
declaratory relief, stating that their "Caltex
Hooded Pump Contest" did not violate
anti-lottery provisions as it did not involve
consideration, allowing Caltex to use the
mails for the contest.

The Court clarified that the term "lottery"

includes schemes with the elements of
prize, chance, and consideration.

Purpose of Alonzo v. IAC, The Alonzo v. Intermediate Appellate Court It is a cardinal rule that, in
Construction G.R. 72873 case involves the interpretation and seeking the meaning of the law,
application of the right of redemption in the the first concern of the judge
context of co-heirs selling their hereditary should be to discover in its
rights. provisions the intent of the
lawmaker.
The case involves a parcel of land inherited
by five siblings. Two siblings (Celestino & Thus, we interpret and apply the
Eustaquia) sold their shares to the same law not independently of but in
vendee, the Alonzos. On February 25, 1976, consonance with justice.
Mariano Padua, another co-heir, sought to
redeem the area but his complaint was Law and justice are inseparable,
dismissed as he was an American citizen. and we must keep them so.
Tecla Padua, another co-heir, filed her own
complaint invoking the right of redemption. There are some laws that while
The trial court dismissed her complaint, generally valid, may seem
ruling that the right had lapsed as it was not arbitrary when applied in a
exercised within thirty days from notice of particular case because of its
the sales in 1963 and 1964. The court held peculiar circumstance.
that actual knowledge of the sales by the
co-heirs satisfied the legal requirement. The In such a situation, what we do is
Intermediate Appellate Court reversed this find a balance between the word
decision, stating that written notice was and the will that justice may be
required under Article 1088 of the Civil done and the law is obeyed.
Code. Justice is always an essential
ingredient of its decisions.
The court recognized that the co-heirs were
undeniably informed of the sales, even
though no written notice was given to them.

The Supreme Court deviated from the strict

letter of the law and adopted an exception

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to the general rule based on the peculiar

circumstances of the case, in order to
achieve justice.

Purpose of Nitafan v. CIR, Nitafan v. Commissioner of Internal The primary task in

Construction G.R. No. 78780 Revenue involved judges in the Regional constitutional construction is to
Trial Court who sought to prohibit the ascertain and thereafter assure
deduction of withholding taxes from their the realization of the purpose of
salaries. They argued that any tax withheld the framers and of the people in
from their salaries would constitute a the adoption of the Constitution.
decrease or diminution of their salaries, The ascertainment of that intent
which is contrary to the provision of Section is in keeping with the
10, Article VIII of the Constitution. fundamental principle of
constitutional construction that
The Court examined the deliberations of the the intent of the framers of the
1986 Constitutional Commission and found organic law and of the people
that the intent of the framers was to delete adopting it should be given
the proposed exemption from income tax effect.
for members of the Judiciary. The Court
emphasized that the salaries of judges are
properly subject to a general income tax
law applicable to all income earners.

The Philippine Supreme Court ruled that the

deduction of withholding taxes from the
salaries of judges does not constitute a
decrease or diminution of their salaries and
is in accordance with the intent of the
Constitutional Commission.

Purpose of People v The President of a national bank is found In the interpretation and
Construction Concepcion, guilty of violating the law by granting a construction of statutes, the
44 Phil. 126 credit to a partnership where his wife is a primary rule is to ascertain and
member, resulting in imprisonment, a fine, give effect to the intention of the
and costs. Legislature.

Concepcion was charged with violating

section 35 of Act No. 2747. Section 35
prohibited the bank from granting loans,
directly or indirectly, to any members of the
board of directors or agents of the branch
banks – The defendant authorized a credit
extension of P300,000 to a partnership
called "Puno y Concepcion, S. en C." which
included his wife as a member.

The court determined that the granting of

the credit constituted a loan within the
meaning of section 35 of Act No. 2747. The
credit was granted through the issuance of
demand notes, which were later paid by the
partnership. In this case, the demand notes
were not discount paper but were evidence
of indebtedness, as interest was paid when
the notes fell due.

Based on its review of the evidence and the

arguments presented, the court affirmed
the judgment of the trial court. The
defendant was found guilty of the crime

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charged and the court imposed the penalty

within the limits of the law.

Power to Endencia v. The case of Endencia v. David involves the While the duty of the Legislative
Construe David, G.R. Nos. collection of income tax on the salaries of and the Executive departments
L-6355-56 judicial officers in the Philippines. They are enacting and enforcing a law
argued that such collection is a diminution respectively, the Judiciary may
of their compensation and violates the construe or interpret the law and
Constitution. has the final word as to what the
law means.
The Supreme Court ruled in favor of the
plaintiffs, stating that the collection of
income tax on the salaries of judicial
officers is indeed a diminution of their
compensation and therefore
unconstitutional. The Court emphasized
that the interpretation and application of
laws, including the Constitution, is the
exclusive jurisdiction of the judicial
department. The Legislature cannot limit or
restrict the power granted to the courts by
the Constitution.

Limitation on the Tanada v. Yulo, The case of Taňada v. Yulo involves Juan Legislative intent must be
Power to G.R. No. 43575 Taňada, who was appointed as a justice of determined from the language of
Construe the peace in Alabat, Tayabas on December the statute itself. Complex ideas
4, 1911. Taňada was transferred to the can't be made clear by using
same position in Sept. 8, 1964 in the confusing language and trying to
Municipality of Perez, Tayabas, pursuant to find hidden meanings that don't
section 206 of the Revised Administrative match the words used. Trying to
Code. Taňada reached the age of sixty-five do this is risky and could easily
on October 5, 1934. Following this, the result in changing the law
Judge of First Instance of Tayabas, acting through judicial construction. To
on instructions from the Department of depart from the meaning
Justice, directed Taňada to cease acting as expressed by the words is to
justice of the peace of Perez, Tayabas. alter the statute is to legislate
Taňada surrendered his office under protest not to interpret.
and subsequently filed an original action of
quo warranto to challenge his removal.

The Supreme Court ruled that Act No. 3899

does not apply to Taňada, as he reached
the age of sixty-five after the specified date
of January 1, 1933. The Court also ruled
that Taňada's transfer did not constitute a
new appointment and thus did not bring
him under the purview of Act No. 3899.

The Court emphasized that the language of

the statute must be interpreted as it is
written, without inserting words or phrases
that were not included by the legislature.
The Court reaffirmed its earlier decision in
the case of Regalado v. Yulo, which held
that justices of the peace who reached the
age of sixty-five after January 1, 1933, were
not affected by Act No. 3899. Consequently,
the Court ordered that Taňada be reinstated
to his position as justice of the peace of
Perez, Tayabas, without any special

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pronouncement as to costs.

Limitation on the Floresca v. The case involves the unlawful dismissal of Doctrine of political question is
Power to Philex, G.R. No. Imelda Salazar by Globe-Mackay Cable and beyond the ambit of judicial
Construe L-30642 Radio Corporation (GMCR). Salazar filed a review.
complaint against GMCR for illegal
suspension and dismissal, among other
claims.

Literal Tanada v. Yulo The Court reaffirmed its earlier decision in The law is clear in its plain and
Interpretation; (supra) the case of Regalado v. Yulo, which held literal meaning, and should not
Verba Legis that justices of the peace who reached the have been construed in another
age of sixty-five after January 1, 1933, were way.
not affected by Act No. 3899. Consequently,
the Court ordered that Taňada be reinstated
to his position as justice of the peace of
Perez, Tayabas, without any special
pronouncement as to costs.

Literal Globe-Mackay A general systems analyst is placed under If a statute is clear and
Interpretation; Cable and Radio preventive suspension for a month and unambiguous, it should be given
Verba Legis Corporation v. later illegally dismissed by her employer its literal meaning and applied
NLRC and after being found to have violated company without interpretation.
Salazar, G.R. No. regulations, leading to a legal battle over
82511 the justification of the suspension and
lawfulness of the dismissal.

Under Art. 279 of the Labor Code, where a

case of unlawful or unauthorized dismissal
has been proved by the aggrieved
employee, or on the other hand, the
employer whose duty it is to prove the
lawfulness or justness of his act of
dismissal has failed to do so, then the
remedies provided in Article 279 should
find application.

To go back to the instant case, there being

no evidence to show an authorized, much
less a legal, cause for the dismissal of
private respondent, she had every right, not
only to be entitled to reinstatement, but as
well, to full backwages. The principle of
“strained relations” cannot be accepted
since her job as systems analyst is not one
characterized as a position of trust. Loss of
confidence cannot also be accepted since
it must rest upon a valid basis.

Literal Saguisag et.al. v. The case involves the constitutionality of Verba legis is the paramount
Interpretation; Ochoa, et.al., the Enhanced Defense Cooperation consideration. The courts will not
Verba Legis G.R. No. 212426 Agreement (EDCA) in the Philippines. The stop at verba legis but that is
petitioners argue that the EDCA should where they should begin. Thus,
have required Senate concurrence to be when the true intent of the law is
considered constitutional. The Supreme clear but not reflected in the
Court ultimately upholds the EDCA as words, the situation calls for the
constitutional, with Chief Justice Maria application of the cardinal rule of
Lourdes Sereno writing the majority construction that such intent or
opinion. spirit must prevail over the letter.

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Petitioners' own interpretation

and application of the verba legis
rule will in fact result in an
absurdity, which legal
construction strictly abhors. If
this Court accepts the essence
of their argument that every
instance of entry by foreign
bases, troops, and facilities must
be set out in detail in a new
treaty, then the resulting
bureaucratic impossibility of
negotiating a treaty for the entry
of a head of State's or military
officer's security detail, meetings
of foreign military officials in the
country, and indeed military
exercises such as Balikatan will
occupy much of, if not all of the
official working time by various
government agencies. This is
precisely the reason why any
valid mode of interpretation must
take into account how the law is
exercised and its goals effected.
Ut res magis valeat quam pereat.

Petitioners' own interpretation

and application of the verba legis
rule will in fact result in an
absurdity, which legal
construction strictly abhors. If
this Court accept the essence of
their argument that every
instance of entry by foreign
bases, troops, and facilities must
be set out in detail in a new
treaty, then the resulting
bureaucratic impossibility of
negotiating a treaty for the entry
of a head of State's or military
officer's security detail, meetings
of foreign military officials in the
country, and indeed military
exercises such as Balikatan will
occupy much of, if not all of the
official working time by various
government agencies. This is
precisely the reason why any
valid mode of interpretation must
take into account how the law is
exercised and its goals effected.
Ut res magis valeat quam pereat.

Spirit of the law; Alonzo v. IAC, In a case involving the right of

The court recognized that the co-heirs were
Ratio Legis (supra) redemption, the Supreme Court
undeniably informed of the sales, even
deviates from the strict letter of
the law and allows the exercise
of the right despite the lack of
written notice, based on the

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 Statutory Construction Notes - Atty. Carla Bayquen
TOPIC CASE SUMMARY STATCON APPLICATION

though no written notice was given to them. peculiar circumstances of the

case.

Spirit of the law; Salvacion v. A court rules that it has jurisdiction to The Court departed from the
Ratio Legis Central Bank, entertain a complaint filed against a literal application of the
G.R. No. defendant for damages arising from the questioned statute despite being
94723 rape and kidnapping of a minor, and that clear as its application will result
the exemption of foreign currency deposits in a grave injustice which the
should not apply to the defendant, a foreign Court believes to have never
transient, in order to prevent injustice to the been the intention of the
citizen plaintiffs. Legislature.

Spirit of the law; People v. The court ruled in favor of the defendants, The Primary rule is to search for
Ratio Legis Purisima, G.R. stating that the Informations filed by the and determine the intent and
No. L-42050-66 People did not sufficiently allege the spirit of the law. Legislative
necessary elements of the offense under intent is the controlling factor for
Presidential Decree No. 9. The court whatever is within the spirit of a
emphasized the need for strict construction statute, and this has to be so if
of penal statutes and the importance of strict adherence to the letter
considering the intent and spirit of the law. would result in absurdity,
The court highlighted the importance of fair injustice and contradictions.
and just evaluation of cases by police
authorities and the prosecuting arm of the
government.

Spirit of the law; Matabuena v. A dispute arises over a donation made by a Necessary implication of the
Ratio Legis Cervantes, 38 man to his common-law wife, leading to a application of ratio legis. If there
SCRA 284 Supreme Court ruling that the donation is is ever any occasion where the
void, but the widow is still entitled to half of principle of statutory
the inheritance. construction that what is within
the spirit of law is as much a part
The lower court ruled in favor of Petronila, of it as what is written, this is it
stating that the donation was made before and otherwise the basic purpose
their marriage and therefore valid. The discernible in such codal
Supreme Court held that the prohibition provision would not be attained.
against donations between spouses during
marriage, as stated in Article 133 of the
Civil Code, should also apply to
common-law relationships. The court cited
a 1954 Court of Appeals decision,
Buenaventura v. Bautista, which declared a
donation between common-law spouses as
null and void.

When Del Mar v. The court ruled that the Philippine The statute admits of different
Construction PAGCOR, G.R. Amusement and Gaming Corporation interpretations is the best
Necessary No. 138298 (PAGCOR) has a valid franchise to operate evidence that the statute is
jai-alai games by itself, but not in vague and ambiguous. It is
association with any other person or entity, widely acknowledged that a
declaring the agreement between PAGCOR, statute is ambiguous when it is
Belle Jai-Alai Corporation (BELLE), and capable of being understood by
Filipinas Gaming Entertainment Totalizator reasonably well-informed
Corporation (FILGAME) to be without force persons in either of two or more
and effect. senses.

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 Statutory Construction Notes - Atty. Carla Bayquen
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When People v. Eusebio Nazario is convicted for failing to The Supreme Court had
Construction Nazario, G.R. No. pay municipal taxes for his fishpond, as the occasion to define vagueness as
Necessary L-44143 Supreme Court rules in favor of the when a law “lacks
prosecution, stating that the municipal comprehensible standards that
ordinances were clear and constitutional. men of common intelligence
must necessarily guess as to its
meaning and differ as to its
application.”

It went on to say that a law “must

be utterly vague on its face and
cannot be clarified by a saving
clause or construction.”

Vague statute – totally devoid of

any means to ascertain the
meaning of the law and what
acts it seeks to enforce or
prevent.

When In re: Allen, G.R. The petitioner, Frank Stanley Allen, who is The way government officials
Construction No. 1455 an alien, claims that he is unlawfully interpret a statute when
Necessary detained and restrained of his liberty in executing it should guide the
Manila, P.I., by W. Morgan Shuster, as Court’s interpretation. However, if
Collector of Customs for the Philippine the government’s interpretation
Archipelago, who threatens to deport the is clearly wrong, it is subject to
petitioner from the Islands for the reason construction.
that said Collector claims that the petitioner
is a prohibited alien contract laborer whose
importation is forbidden by the act of
Congress approved March 3, 1903, entitled
"An act to regulate the immigration of aliens
into the United States”.

The question as to whether the petitioner is

or is not within the class of persons
excluded by that act is not raised in this
stage of the proceedings, and so the only
question to be determined is this: Has the
Collector of Customs for the Philippine
Archipelago lawful authority to execute, or
cause to be executed, so much of said act
of Congress as provides for the detention
and deportation of prohibited aliens?

Clerical Error Lopez & Sons, The Court of Tax Appeals lacks jurisdiction Clerical errors committed by the
Inc. v. CTA, G.R. to review decisions of the Collector of legislature may also be the
No. L-9274 Customs, as the Commissioner of Customs subject matter of statutory
has the authority to review such decisions, construction. Here, the analysis
and a clerical error in the law should have does not start with determining
included the Commissioner of Customs in the true intention of the
Section 11. legislature. But rather if a clerical
error has been committed, the
● The Court held that the Court of
real intention of the legislature
Tax Appeals has jurisdiction to
can be determined by the
review decisions of the
principles of construction.
Commissioner of Customs.
● The discrepancy between Sections
7 and 11 should be harmonized to
give effect to the entire Act.

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Interpretations of Centeno v. In Centeno v. Villalon-Pornillos, the Penal laws are to be construed

Certain Statutes: Villalon Pornillos, Supreme Court ruled that solicitations for strictly against the state and in
Penal Laws G.R. No. 113092 religious purposes are not covered by the favor of the accused.
requirement of securing a permit under
Presidential Decree No. 1564, as the law If the statute is ambiguous and
specifically mentions "charitable purposes" admits two reasonable but
and "public welfare purposes" but does not contradictory constructions, that
include solicitations for religious purposes which operates in favor of a
unless explicitly stated. party accused under its
provisions is to be preferred.
● The Court highlighted the principle
of statutory construction that penal
laws should be construed strictly
against the State and liberally in
favor of the accused.
● It stated that acts that are innocent
and lawful should not be held as
criminal unless there is a clear and
unequivocal expression of
legislative intent to make them so.
● The Court concluded that
solicitation for religious purposes
may be subject to regulation by the
State, but in this case, the law does
not cover solicitations intended for
religious purposes

Interpretations of U.S. v. Go Chico, In the Philippine Jurisprudence case, In many crimes, the intention of
Certain Statutes: G.R. No. 4963 defendant Go Chico is charged with the person committing the crime
Penal Laws violating a law that prohibits the display of is immaterial, as the act itself
flags, emblems, or devices used during the produces the pernicious effect
insurrection in the Philippine Islands, and that the statute seeks to avoid.
the court rules that a criminal intent is not
necessary for a violation of the statute and The court stated that it would be
that the law applies to any flag of that type, nonsensical to interpret the law
not just the exact ones used in the as only applying to the exact
insurrection. flags used, as it would nullify the
statute.

Interpretations of Marinduque Iron Marinduque Iron Mines Agents, Inc. A statute will not be construed
Certain Statutes: Mines v. challenges the validity of an ordinance as imposing a tax unless it does
Tax Laws Municipal imposed by the Municipal Council of so, clearly, expressly and
Council, G.R. No. Hinabangan, Samar, which levied an invalid unambiguously.
L-18924 municipal license tax on the gross outputs It is an ancient principle that a
of mines and other businesses, resulting in tax cannot be imposed without
the Court declaring the ordinance null and clear and express words for that
void due to its violation of the prohibition on purpose.
municipalities imposing taxes based on
sales. Implied tax imposition is not
allowed and tax laws are
interpreted strictly, especially
with penalties involved.

Interpretations of NPC v. City of The case revolves around the authority of If the tax statute in question
Certain Statutes: Cabanatuan, G.R. the Secretary of Labor and Employment to clearly, expressly and
Tax Laws No. 149110 assume jurisdiction over a labor dispute unambiguously states that a
and its incidental controversies. This person, thing, activity covered by
authority includes unfair labor practice the tax statute and the taxpayer
cases that may cause or likely to cause a is claiming tax exemption, the
strike or lockout in an industry burden shifts to the taxpayer to

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 Statutory Construction Notes - Atty. Carla Bayquen
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indispensable to the national interest. The establish the basis for

Secretary's power to consolidate cases and exemption.
assume jurisdiction aims to efficiently and
effectively resolve the labor dispute.
The Court emphasized that taxes
The Supreme Court ruled that the City of are essential for the government
Cabanatuan has the authority to impose a to fulfill its mandate of
franchise tax on the National Power promoting the general welfare.
Corporation (NPC), a government-owned The grant of taxing powers to
corporation, and that NPC is not exempt local government units aligns
from paying taxes as a non-profit with the policy of local autonomy
organization. and decentralization of
governance.

Interpretations of International The dispute arose due to a deadlock in the The rule is that all doubts in the
Certain Statutes: Pharmaceuticals, negotiation for a collective bargaining interpretation and
Social Inc. v. Secretary agreement. The ALU filed a notice of strike, implementation of labor laws
Legislation of Labor, G.R. No. which led to a complete paralysis of the should be resolved in favor of
92981 company's operations. Three other labor labor.
cases were filed with the National Labor
Relations Commission (NLRC) by both
parties.

The Supreme Court ruled that the Secretary

of Labor has the power to assume
jurisdiction over labor disputes and its
incidental controversies, upholding the
validity of Section 6, Rule V of the Revised
Rules of the NLRC, in order to promote the
efficient and expeditious resolution of labor
disputes.

Interpretations of Office of the An administrative complaint against a court Rules of Procedure’s rules are
Certain Statutes: Court interpreter convicted of a crime involving indispensable to the prevention
Rules of Court Administrator v. moral turpitude is put on hold pending the of delays and speedy discharge
Garong, A.M. No. outcome of his appeal, as the court of judicial business.
P-99-1311 emphasizes the importance of procedural
rules while recognizing the need for Strict compliance with such rules
substantial justice. is mandatory and imperative.

However, if a stringent
application of the rules would
hinder rather than serve the
demands of substantial justice,
the former must yield to the
latter.

Interpretations of Provincial Sheriff The Provincial Sheriff of Rizal and Charles While the rules of procedures are
Certain Statutes: of Rizal v. CA, Hollmann are held solidarily liable for the liberally construed, the
Rules of Court et.al., G.R. No. irregular and void auction sale of Sandra provisions on reglementary
L-22606 Shaouy's personal properties, which were periods are strictly applied as
sold at scandalously low prices and on a they are deemed indispensable
different date than advertised, resulting in to the prevention of needless
the annulment of the sale and the delays and necessary to the
condemnation of the petitioners to pay orderly and speedy discharge of
Shaouy the sum of P3,404 with legal judicial business.
interest.

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Interpretations of Duncan v. CFI, In the case of Duncan v. Court of First The application of ancient
Certain Statutes: G.R. No.L-30576 Instance of Rizal, the Supreme Court ruled Roman legal maxim "Dura lex
Law on Adoption that the consent of the unidentified mother sed lex" in adoption of children,
was not necessary for adoption, and however, should be softened so
declared the child as the adopted child and as to apply the law with less
heir of the petitioners based on the de facto severity and with compassion
guardian's consent and the best interests of and humane understanding, for
the child. adoption is more for the benefit
of unfortunate children,
particularly those born out of
wedlock, than for those born with
a silver spoon in their mouths.

Interpretations of San Juan v. CSC, The Supreme Court ruled in favor of the Where a law is capable of two
Certain Statutes: G.R. No. 92299 governor, stating that he has the sole right interpretations, one in favor of
Local to recommend nominees for the position of centralized power in Malacañang
Government/ Provincial Budget Officer, nullifying the and the other beneficial to local
Local Autonomy appointment made by the Department of autonomy, the scales must be
Budget and Management (DBM). weighed in favor of autonomy.

Interpretations of Bagong Bayani v. The case of Ang Bagong Bayani v. While the enumeration is not
Certain Statutes: COMELEC, G.R. Commission on Elections challenges the exclusive, it demonstrates the
Constitution No. 147589 participation of mainstream political parties clear intent of the law that not all
and non-marginalized groups in the sectors can be represented
party-list elections, arguing that the system under the party-list system.
was intended for marginalized and
underrepresented groups; the Supreme The party-list system is a tool for
Court found the petition partly meritorious the benefit of the
and directed the Comelec to conduct underprivileged; the law could
summary evidentiary hearings on the not have given the same tool to
qualifications of party-list participants, others, to the prejudice of the
emphasizing the importance of the system intended beneficiaries.
in giving marginalized groups a voice in
Congress. The intent of the Constitution is
to give genuine power to the
people by enabling them to
become veritable lawmakers
themselves. Nevertheless, the
Comelec must ensure that only
Filipinos who are “marginalized
and underrepresented” may
become members of Congress
under the party-list system,
Filipino-style.

Interpretations of Manila Prince The Manila Prince Hotel v. Government Art. II of the Constitution, is
Certain Statutes: Hotel v. GSIS, Service Insurance System case clarified usually not self-executing.
Constitution G.R. No. 122156 that the constitutional provision on national However, the Court also held that
patrimony is self-executing and requires a provision which is complete in
preference for qualified Filipinos in the itself and becomes operative
grant of rights, privileges, and concessions without aid of an enabling
covering the national economy and legislation, or that which supplies
patrimony, resulting in the Supreme Court sufficient rule by means of which
ordering the respondents to accept the the right it grants may be enjoyed
matching bid of the Manila Prince Hotel to or protected, is self-executing.
protect the Manila Hotel as part of the
national patrimony. Under the doctrine of
constitutional supremacy, if a
● The court determines that the
law or contract violates any norm
provision is self-executing and
of the constitution that law or

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 Statutory Construction Notes - Atty. Carla Bayquen
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does not need further legislation to contract whether promulgated by

be enforced. the legislative or by the executive
● The provision is clear in its branch or entered into by private
language and does not empower persons for private purposes is
the legislature to prescribe the null and void and without any
means by which the policy should force and effect.
be carried out.

Interpretations of Francisco v. HOR, The Court declares the second Applying the principles of
Certain Statutes: G.R. No. 160261 impeachment complaint against Chief constitutional construction, ut
Constitution Justice Davide Jr. to be unconstitutional magis valeat quam pereat. The
and time-barred, emphasizing the Constitution is to be interpreted
importance of judicial review in upholding as a whole, the said provision
constitutional provisions on impeachment should function to the full extent
proceedings. of its substance and form and its
terms, in conjunction with all
● The Court has a duty under Article other provisions of the
VIII, Section 1 of the 1987 Constitution.
Constitution to settle actual
controversies involving rights that
are legally demandable and
enforceable.
● The issues raised are justiciable
and not merely political questions,
as they involve the interpretation of
constitutional provisions.

Interpretations of De Castro v. JBC, The case of De Castro v. Judicial and Bar This is consistent with the rule
Certain Statutes: G.R. No. 191002 Council addressed the issue of whether the that every part of the statute
Constitution incumbent President can appoint the must be interpreted with
successor of Chief Justice Puno during the reference to the context.
prohibition period, with the Supreme Court
ruling that the prohibition does not apply to If the framers intended Section
appointments in the Judiciary and allowing 15 to cover all kinds of
the President to appoint the successor presidential appointments, they
within 90 days of the vacancy. would have easily and surely
inserted a similar prohibition.
● The JBC was established to
de-politicize the Judiciary and
To hold that Section 15 extends
ensure merit-based appointments.
to appointments to the Judiciary
● The 90-day period for filling
undermines the intent of the
Supreme Court vacancies, as
Constitution of ensuring the
mandated by Section 4 (1), Article
independence of the Judicial
VIII, is a special provision that
Department for it will tie the
operates independently of the
Judiciary and the SC to the
prohibition in Section 15, Article VII.
fortunes or misfortunes of
● The JBC's duty to submit a list of
political leaders vying for the
nominees before the President's
Presidency in a presidential
mandatory 90-day period to appoint
election.
is ministerial, and any delay would
be unconscionable.
● The incumbent President has the
authority to appoint the successor
of Chief Justice Puno within the
90-day period from the vacancy,

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 Statutory Construction Notes - Atty. Carla Bayquen
TOPIC CASE SUMMARY STATCON APPLICATION

and the JBC must submit the

shortlist of nominees to the
President on or before May 17,
2010.

Interpretations of Chavez v. JBC, The Supreme Court declares the current It is a well-settled principle of
Certain Statutes: G.R. No. 202242 composition of the Judicial and Bar Council constitutional construction that
Constitution unconstitutional, ruling that only one the language employed in the
member of Congress should sit as a Constitution must be given its
representative, in accordance with the ordinary meaning except where
constitution. The Court emphasizes the technical terms are employed.
need to preserve the distinction between
the Senate and the House of As much as possible, the words
Representatives in the JBC. of the Constitution should be
understood in the sense they
● The decision highlighted the
have in common use.
principle of checks and balances,
stating that the JBC was designed
to insulate the judiciary from
political pressure and partisan
activities.
● The Court concluded that the
current practice of having two
representatives from Congress with
one vote each is a constitutional
circumvention that cannot be
countenanced

Interpretations of David v. SET, G.R. A foundling's citizenship is questioned in a Reading a constitutional

Certain Statutes: No. 221538 legal battle to unseat her as a Senator, but provision requires awareness of
Constitution the court rules in her favor, affirming her its relation with the whole of the
natural-born citizenship and qualification Constitution, it should be read as
for office. a singular, whole unit – ut magis
valeat quam pereat.
● The SET's conclusions were
consistent with a reasonable
A provision is not to be
interpretation of the Constitution,
separated from all others and
considering the unique
considered alone, they are not
circumstances of foundlings
allowed to defeat one another if
● Substantial evidence, such as the
by any reasonable construction,
circumstances of Poe's
the two can be made to stand
abandonment and her physical
together.
features, supported the inference
that she had Filipino parentage.
The courts must harmonize them
● The constitutional mandate to
in favor of a construction which
protect children's rights and ensure
will render every word operative.
equal protection was highlighted,
arguing that excluding foundlings
from natural-born status would be
discriminatory.
● The Court referenced international
norms and legislative acts that
support the recognition of
foundlings as citizens

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