Verba Legis (literal
words of the law)
and Textualism
(interpreting
statutes based on
their text)
1.​ District of Columbia v. Heller
Ruling in relation to Statutory Construction:
●​ The Supreme Court ruled that the second amendment protects
an individual’s right to possess firearms unconnected with
services in a militia and to use them for traditionally lawful
purposes, such as self-defense within the home. This
interpretation diverged from previous understandings that limited
the right to bear arms primarily to militia service.
●​ “Verba legis” emphasizes interpreting legal texts based on their
literal meaning. In Heller, Scalia’s majority opinion focused on
the text of the Second Amendment, analyzing its language
closely.
●​ The court distinguished between the prefatory clause (“A well
regulated militia, being necessary to the security of a free state”)
and the operative clause (“the right of the people to keep and
bear arms shall not be infringed”). The majority concluded that
while the prefatory clause provided context, it did not limit the
operative clause.
●​ Court asserted that the right to keep and bear arms is an
individual right, independent of militia service.
●​ Textualism prioritizes text’s plain meaning at the time it was
written.
●​ Constitutional rights should be interpreted based on their textual
meaning rather than inferred from broader policy considerations
or legislative intent.
2.​ JM Tuason & Co., Inc. v. Land Tenure Administration
Ruling in relation to Statutory Construction:
●​ The constitutionality of RA 2616, which authorized the
expropriation of the Tatalon Estate in QC for the purpose of
subdividing and reselling the land to bona fide occupants at cost.
●​ The Supreme Court ruled that RA 2616 did not violate the
constitutional rights of JM Tuason & Co, Inc., affirming that the
act was a valid exercise of Congress’s power of eminent
domain.
●​ Court emphasized that Congress has broad authority to enact
laws for public use, particularly when addressing social issues
like land distribution and housing.
●​ The ruling confirmed congress’s authority to enact laws for
public use while emphaszing that such laws must be interpreted
based on their clear language.
3.​ La Bugal B’laan Tribal Association, Inc. v. Ramos
Ruling in relation to Statutory Construction:
●​ The case involves challenging the unconstitutionality of RA
7942, implementing rules, and the financial and technical
assistance agreement between the government and foreign
mining companies.
●​ Petitioners argued that these laws and agreements violated
constitutional provisions regarding ownership and utilization of
natural resources, particularly indigenous peoples’ rights
●​ The Supreme Court declared certain provisions of RA 7942
unconstitutional, particularly those that allowed foreign
companies to have more than mere financial or technical
assistance
●​ Framers of the constitution discussed the concept of service
contracts as it was understood in the 1973 Constitution, their
intentions were not to ban service contracts but to enact
provision to minimize the abuses that were prevalent during the
martial law regime
●​ Full control and supervision cannot be taken literally to the point
where on would expect the state to manage every single detail
as it would be impossible. The government does not need to
micro-manage mining operations in order to be considered as
exercising full control and super vision.
●​ Control as utilized in sec 2 of article XII must be to mean to a
degree of control sufficient to enable the state to direct, restrain,
regulate, and govern. RA 7942 and DAO 96-49 vests the
government more than a sufficient degree of control and
supervision over the conduct of mining operations.
●​ The court considered histrocial context and legislative intent
behind constitutional provisions on natural resources, reinforcing
that these provisions were designed to protect national interests
and promote social justice
●​ This approach aligns with textualism by ensuring that
interpretations reflect both the text’s ordinary meaning and its
intended purpose as understood at the time of ratification.
4.​ Civil Liberties Union v. Executive Secretary
Ruling in relation to Statutory Construction:
●​ The case involves challenging the EO 284, issued by President
Corazon Aquino, allowing cabinet members and other
high-ranking officials to hold additional government positions
while receiving compensation for those roles.
●​ Petitioners, including the civil liberties union, argued that this EO
violates section 13, Art. VII of the 1987 Constitution, which
prohibits cabinet members from holding any other office or
employment during their tenure.
●​ EO 284 was unconstitutional which emphasizes that the framers
of the Constitution intended to impose strict prohibitions on
cabinet members holding additional offices to prevent potential
conflicts of interest and abuses associated with multiple
government positions
●​ Verba legis: court applied the principle by focusing on the literal
wording of Sec 13, Art VII of the Constitution. The explicit
language prohibiting Cabinet members from holding other
offices was interpreted as an absolute restriction
●​ Textualism: the court’s decision reflected a textualist approach,
where the interpretation relied heavily on the ordinary meaning
of the terms used in the constitution without delving into
legislative intent or border policy considerations
Constitutional
Provision must be
read in relation to
entirety
1.​ David v. Senate Electoral Tribunal
Ruling in relation to Statutory Construction:
●​ The case talks about challenging the natural-born citizenship
status of Grace Poe, arguing that as a foundling with unknown
biological parents, she was not a natural-born citizen and thus
unqualified to hold office under Art VI, Sec 3 of the 1987
Constitution
●​ Supreme Court emphasized that foundlings are presumed to be
natural-born citizens unless substantial evidence suggests
otherwise
●​ Court also emphasized that constitutional provisions should be
interpreted in isolation rather in relation to the entire constitution
and its overarching principles.
●​ Court noted that Art IV, Sec 1 of the 1987 Constitution does not
explicitly exclude foundlings from being considered natural-born
citizens. Instead, it must be understood within the broader
context of the Constitution’s commitment to equality and
protection of rights for all individuals.
●​ Highlighted that interpreting citizenship laws requires
considering the historical context and legislative intent behind
citizenship provisions across different Philippine constitutions
●​ By adopting a holistic approach, the court recognized that
denying foundlings their status as natural-born citizens would
create an unjust and discriminatory class, contrary to the
principles of equal protection and human rights embedded in the
constitution.
2.​ La Bugal B’laan Tribal Association Inc. v. Ramos
Ruling in relation to Statutory Construction:
●​ The court highlighted the importance of interpreting
constitutional provisions in relation to their entirety rather than in
isolation. This holistic approach ensures that the intent behind
the Constitution’s provisions is preserved.
●​ The decision pointed out that while foreign entities can provide
technical or financial assistance, they cannot engage in
operational management or assume beneficial ownership rights
over natural resources.
●​ By reading constitutional provisions together, the Court
reinforced that any interpretation must align with broader
principles of national sovereignty and social justice embedded
within the constitution.
3.​ Co v. Electoral Tribunal
Ruling in relation to Statutory Construction:
●​ The case talks about challenging the citizenship and
●​
●​
●​
●​
●​
qualifications of Jose L. Ong Jr., who was declared a
natural-born citizen and duly elected representative for the
second district of northern samar.
Supreme Court uphled the HRET’s decision, affirming that Jose
L. Ong, is a natural-born citizen of the Philippines based on his
mother’s Filipino citizenship and his father’s naturalization when
Ong was a minor.
Court emphasized that citizenship can be derived from either
parent, and Ong’s status as a natural-born citizen was validly
established.
The SC highlighted the importance of interpreting constitutional
provisions in relation to their entirety rather than in isolation.
Court noted that Art. IV Sec 1 must be understood alongside
other relevant provisions that govern citizenship and public office
qualifications.
Reading these provisions together, the court reinforced that
interpretations should align with the constitution’s overarching
goals of promoting equality and individuals rights.
4.​ Civil Liberties Union v. Executive Secretary
Ruling in relation to Statutory Construction:
●​ By reading Sec 13 together, the Court reinforced that the
framers intended a strict prohibition on holding multiple offices to
promote integrity in public service.
●​ The ruling underscored that any law or executive order must
align with constitutional mandates; thus, no executive action
could contravene constitutional prohibitions.
History of the Text
1.​ La Bugal B’laan Tribal Association, Inc. v. Ramos
Ruling in relation to Statutory Construction:
2.​ District of Columbia v. Heller
Ruling in relation to Statutory Construction:
3.​ Filoteo Jr. v. Sandiganbayan
Ruling in relation to Statutory Construction:
●​ Filoteo, a police investigator was accused of leading an armed
hijacking of a postal delivery van. He was convicted by the
Sandiganbayan for brigandage and subsequently challenged his
conviction before the SC.
●​ The SC ruled that Filoteo’s extrajudicial confession was
admissible despite being made without counsel present, as it
was executed prior to the enactment of the 1987 Constitution,
which mandated such confessions to be in writing and in the
presence of counsel.
●​ The court emphasized that since the confession was made
voluntarily and not obtained through torture or coercion, it could
be used against him.
●​ SC considered the historical context surrounding both the
relevant laws and constitutional provisions. This approach is
crucial in stat con as it helps elucidate legislative intent and how
laws have evolved over time.
●​ Court referenced previous legal standards regarding
confessions and arrests before and after significant
constitutional changes in Philippine law, particularly noting
differences between the 1973 and 1987 constitutions.
4.​ Civil Liberties Union v. Executive Secretary
Ruling in relation to Statutory Construction:
●​ The SC emphasized the importance of understanding the
historical context and legislative intent behind constitutional
provisions when interpreting laws.
●​ Court noted that the framers of the 1987 constitution intended to
impose a stricter prohibition on Cabinet members and their
deputies holding multiple positions due to past abuses during
previous administrations, particularly during Marcos regime.
●​ Historical perspective is crucial in statutory construction as it
helps elucidate why certain provisions were included in the
constitution and how they should be applied in contemporary
governance.
Contemporaneous
Construction
1.​ David v. Senate Electoral Tribunal
Ruling in relation to Statutory Construction:
●​ You cannot rely solely on the deliberations; relying solely on the
deliberations is very weak
●​ Refers to the interpretation given to a statute or constitutional
provision at or near the time it was enacted. This principle is
significant because it reflects the intent of lawmakers and
provides insight into how laws should be applied.
●​ Court noted that interpretations made by legislative bodies or
executive agencies regarding citizenship laws are entitled to
great weight, especially when those interpretations have been
consistently applied over time.
●​ Court recognized that there had been no prior judicial precedent
addressing the citizenship status of foundlings, thus
necessitating a reasonable interpretation by the SET based on
existing laws and societal values.
●​ Decision underscored that statutory interpretation must begin
with the text itself, but when ambiguity arises, contemporaneous
construction can help clarify the legislative intent.
Framer’s Intent
1.​ Co v. Electoral Tribunal
Ruling in relation to Statutory Construction:
●​ SC emphasized the importance of understanding the framer’s
intent when interpreting constitutional provisions. The principle
asserts that the interpretation of laws should align with the
original purpose and objectives envisioned by those who drafted
them.
●​ Court noted that the framers of the constitution intended to
ensure that only qualified individuals could hold office, reflecting
a commitment to uphold democratic principles and protect
electoral integrity.
2.​ Montejo v. COMELEC
Ruling in relation to Statutory Construction:
●​ Montejo challenged COMELEC’s resolution 2736 which
transferred municipalities between legislative districts in leyte.
Montejo argued that this action violated the constitutional
principle of equal representation and sought to transfer another
municipality to balance voter distribution.
●​ The court noted that the framers of the 1987 constitution
intended for Congress to have exclusive authority over the
apportionment and redistricting of legislative districts.
●​ COMELEC was empowered to make minor adjustments, it did
not have the authority to make susbtsance changes like
transferring municipalities between districts.
Self-executing v.
non self-executing
provisions
1.​ Oposa v. Factoran
Ruling in relation to Statutory Construction:
●​ Petition sought to cancel existing timber license agreements
(TLAs) and prevent the issuance of new ones, arguing that
these actions violated their constitutional right to a balanced and
healthful ecology.
●​ SC recognized that while the right to a balanced and healthful
ecology is enshrined in Sec 16, Art. II of the 1987 Philippine
Constitution, is not explicitly listed among the civil and political
rights found in the Bill of Rights.
●​ This right is self-executing, it odes not require additional
legislation to be enforceable. Court stated that this right is
fundamental and judicially enforceable, imposing a duty on the
state to protect and advance ecological integrity.
●​ Non-self executing provisions typically require further legislative
action to implement rights and obligations effectively. The court’s
determination that the right to balanced ecology is self-executing
allows individuals to seek judicial remedies directly based on this
provision.
2.​ Manila Prince Hotel v. GSIS
Ruling in relation to Statutory Construction:
●​ MHC filed a petition to prevent GSIS from selling shares of the
●​
●​
●​
●​
●​
Definition,
Concept, Purpose
of Statutory
Construction
Manila Hotel Corporation to a foreign entity, arguing that such
sale violated the constitutional provision that mandates
preference for qualified Filipinos in grants of rights and privileges
concerning national patrimony,
The court ruled that the provision in question is self-executing.
They emphasized that the language of the provision is clear and
does not require legislative action to implement its intent. It
provides a direct command that can be invoked by individuals or
entities to assert their rights without waiting for additional laws.
Court acknowledged that while some constitutional principles
may not be directly enforceable without further legislative action,
the specific provision regarding preference for qualified Filipinos
is not one of them.
Court held that since MHC was a Filipino corporation and had
matched the highest bid made by a foreign entity, it was entitled
to preference under the self-executing provision.
Ruling reinforced the idea that protecting national patrimony and
ensuring Filipino participation in key economic sectors are
fundamental constitutional mandates.
1.​ Yates v. United States
Ruling in relation to Statutory Construction:
●​ Whether “tangible object” is self-executing in its application. The
court ruled that “tangible object” refers specifically to items used
to record or preserve information, thereby excluding fish from its
definition.
●​ Noscitur a sociis (a word is known by the company it keeps) and
ejusdem generis (general words following specific words should
be read in light of those specific words). These canons guided
the interpretation toward understanding tangible objects as items
related to documentation and information storage rather than all
physical items.
●​ By narrowly interpreting “tangible object” the court aimed to
uphold principles of fair notice and due process, ensuring that
individuals are not prosecuted for actions they could not
reasonably foresee as criminal.
●​ Sarbanes-oxley act was designed to address corporate fraud
and misconduct, not fishing violations, reinforcing the idea that
legislative intent should guide interpretations of statutory
language.
2.​ Caltex v. Palomar
Ruling in relation to Statutory Construction:
●​ SC examined whether Caltex’s contest violated the Postal Law.
Court defined stat con as the “art or process of discovering and
expounding the meaning and intention of the authors of the law
with respect to its application to a given case.”
●​ Court applied principles of statutory construction to interpret
what constitutes a “lottery” under the law. It emphasized that for
an activity to be classified lottery, it must include: consideration,
prize, and chance.
●​ In this case, court found that the contest did not meet the criteria
for being classified as a lottery because there was no
consideration required from participants.
●​ Stat con was to ensure that laws are applied fairly and
consistently while respecting legislative intent. Court aimed to
prevent overly broad interpretations that could unjustly restrict
legitimate promotional activities.
Power to Construe,
limitations
1.​ Robinson v. Shell Oil Company
Ruling in relation to Statutory Construction:
●​ SC held that the term “employees” is ambiguous. Court
emphasized its power to interpret statutes in a manner that
aligns with legislative intent and broader statutory context.
●​ Courts have the power to construe ambiguous terms within
statutes, this power is not limitless. Courts must consider
legislative intent and practical implications of their interpretation.
●​ They expressed concern that excluding former employees from
protection would undermine the effectiveness of the Title VII’s
anti-retaliation provisions.
●​ It recognized that interpreting “employees” to include former
employees is consistent within the overall goal to prevent
discrimination and protect individuals who assert their rights
under the law.
2.​ Endencia v. David
Ruling in relation to Statutory Construction:
●​ Taxation salaries for judges, which stated that no salary received
by public officers shall be exempt from income taxes.
●​ SC ruled that sec 13 RA 590 was unconstitutional because it
violated the principle of separation of powers. Court asserted
that only the judiciary has the power to interpret laws and
ascertain their meaning in relation to constitutional provisions.
●​ Ruling highlighted that while the legislature has the authority to
enact laws, it cannot dictate how those laws should be
interpreted in a way that contravenes established judicial
interpretations or constitutional provisions.
●​ Court reiterated that legislative act cannot provide a binding
interpretation on the court regarding constitutional matters. This
principle is crucial to maintaining the independence of the
judiciary and preventing legislative overreach into judicial
functions.
Extrinsic Aids to
Construction
a.​ In general
1.​ Ebarle v. Sucaldito
Ruling in relation to Statutory Construction:
●​ SC emphasized that when interpreting statutes, courts can
utilize extrinsic aids to clarify ambiguities or ascertain legislative
intent. Extrinsic aids include legislative history, administrative
interpretations, and other relevant materials that provide context
for unbderstanding statutory provisions.
●​ Court considered the provisions of EO 264 as an extrinsic aid in
interpreting the procedural requirements for filing complaints
against public officials. The court noted that adherence to these
procedural guidelines was essential for ensuring fairness in the
prosecution of government officials.
2.​ Hidalgo v. Hidalgo
Ruling in relation to Statutory Construction:
●​ SC examined Section 12 of RA 3844 which provides tenants
with a right of redemption when agricultural land is sold. The key
issue was whether this right extended to share tenants or is
limited to agricultural lessees.
●​ In interpreting this provision, the court utilized extrinsic aids such
as legislative history and intent to ascertain the purpose behind
the law. The court noted that the law aimd to protect tenants’
rights and promote equitable access to land ownership.
●​ The use of epigraph.
●​ The very essence of the agricultural land reform code is the
abolition of agricultural share tenancy as probclaimed in its title.
SEc 4 expressly outlaws agricultural share tenancy as “contrary
to public policy” and decrees its abolition.
●​ This is a form of social legislation that must be liberally
construed in favor of the class of persons to be benefited.
B. Legislative
History
1.​ Song Kiat Chocolate Factory v. Central Bank
Ruling in relation to Statutory Construction:
●​ Seeking exemption where the factory argued that cocoa beans
should be classified as chocolate for tax exemption purposes
●​ SC ruled that cocoa beans cannot be considered chocolate
under RA 601. Court examined the legislative history
surrounding the law.
●​ Chocolate refers to a finished product made from processed
cocoa beans and distinguishes this from raw cocoa beans. The
legislative intent was to provide exemptions for manufactured
goods rather than raw materials.
C.
Contemporaneous
Construction
1.​ Nestle Philippines Inc. v. Court Of Appeals
Ruling in relation to Statutory Construction:
●​ Sought for exemption from registration its transaction involving
the issuance of additional shares to its existing stockholders if
the unissued portion of the authorized capital stock.
●​ Court ruled the case relying on the interpretation of the SEC,
which ruled that the phrase “the issuance of additional capital
stock of a corporation sold or distributed by it among its
stockholders” is applicable only where there is an increase in the
authorized capital stock of a corporation
●​ Courts give much weight to contemporaneous construction
because of the respect due to the government agency or
officials charged with the implementaion of the law, their
competence, expertness, experience and informed judgement,
and the fact that they frequently are the drafters of the law they
interpret.
IV. Interpretation of
words and phrases
in a statute
1.​ Ramirez v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ The law applied to the case is clear and unambiguous and leave
us with no discretion.
●​ The statutes intent to penalize all persons unauthorizzed to
make such recording is underscored by the use of the qualifier
“any”
●​ Lawmakers indeed contemplated to make illegal, unauthorized
tape recordings of private conversations or communications
taken either by the parties themselves or by third persons
a.​ General v.
Particular
2.​ Lokin v. Commission on Elections
Ruling in relation to Statutory Construction:
●​ Sec 8 clearly enumerates specific circumstances under which a
party-list organization can substitute nominees
●​ Court highlighted that these exceptions are to be construed
strictly, meaning that any additional grounds for substitution
must not be allowed unless explicitly stated in the law.
●​ Ruling reinforced that administrative rules must remain
consistent with the laws they implement, they cannot override or
modify statutory provisions.
●​ The decision clarified that any ambiguity in statutory language
should be resolved by adhering strictly to the legislative intent as
expressed in the law itself.
B. Ejusdem
Generis
1.​ Yates v. United States
Ruling in relation to Statutory Construction:
●​ States thet when a general term follows specific terms in a
statutory list, the general term is interpreted to include only items
of the same type of those list. In this case, the specific terms
“records” and “documents” were considered.
2.​ Cagayan Valley Enterprises v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ General term “lawful beverages” should be construed in light of
the specific enumeration of soda water, mineral or aerated
waters, cider, milk, which ostensibly constitutes a class of
non-alcoholic beverages.
●​ The title clearly shows the legislative intent to give protection to
all marked bottled and containers of all lawful beverages
regardless of their nature.
●​ “Other lawful beverages” is used in its general sense, referring
to all beverages not prohibited by law. Beverage is defined as a
liquor or liquid for drinking.
●​ Court made use of the title of the statute to aid it in its
interpretation
●​ Rule of ejusdem generis CANNOT be applied in this case. To
limit the coverage of rge law only to those enumerated or of the
same kind or class will defeat the purpose of the law. Such rule
of ejusdem generis is to be resorted to only for the purpose of
determining what the intent of the legislature was in enacting the
law.
●​ Construction consistent with justice/construction that avoids
absurdity
3.​ Commissioner of Internal Revenue v. AMEX
Ruling in relation to Statutory Construction:
●​ “And other similar services” which puts AMEX activities under
the purview of VAT zero-rated transaction.
●​ Ejusdem generis is not applicable in the provision.
●​ Such words do not constitute a readily discernible class and are
patently not of the same kind
●​ There is the regulatory intent to give the general phrase “and
other similar service” a broader meaning. Clearly, the preceding
phrase “as well as” is not meant to limit the affect of “and other
similar services”
●​ The statutory provision upon which this regulation is based is by
itself not restrictive. The scope of the word “services” in section
102 (b)(2) of the tax code is broad; it is not susceptible of narrow
interpretation.
C. Noscitur a sociis
1.​ Co Kim Chan v. Valdez Tan
Ruling in relation to Statutory Construction:
●​ “All laws, regulations, and processes” are null and void and
without legal effect
●​ “Processes” cannot be interpreted to mean judicial processes;
we did not deem it necessary to specify the processes to which
said proclamation should be construed to refer
2.​ Yates v. United States
Ruling in relation to Statutory Construction:
●​ “Tangible object” in conjunction with “records” and “documents”
which are explicitly mentioned. By applying the maxim, court
reasoned that since “records” and “documents” are associated
with information preservation, the term “tangible object” should
similarly be interpreted to refer to items used for recording or
preserving information.
●​ Court favored the narrower interpretation concluding that
“tangible object” does not encompass all physical items but is
limited to those that serve a similar purpose as records and
documents.
D. Expressio unios
est exclusio
alterius
1.​ National Power Corporation v. City of Cabanatuan
Ruling in relation to Statutory Construction:
●​ Court noted that sec 193 broadly stated that all previous
exemptions were withdraws, it also specified exemptions for
certain entities like local water, districts, and cooperatives. The
explicit mention of these exceptions implied that other entities,
including NPC, were not exempt from taxation.
●​ Ir is basic percept of statutory construction that the express of
one person, thing, act, or consequence excludes all others as
expressed in the familiar maxim expressio unius est exclusio
alterius. Not being a local water district, a cooperative registered
under RA 6938, or a nonstock and non profit hospital or
educational institution, petitioner clearly does not belong to the
exemption. It is therefore incumbent upon the petitioner to point
to some provisions of the LGC that expressly granny it
exemption from local taxes.
2.​ Primero v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ “Bladed, pointed, or blunt weapon such as Fanknife, spear,
dagger, bolo, balisong, barong, kris”
●​ Enumeration of specified matters in a statute is construed as an
exclusion of matters not enumerated unless a different intention
appears. The maxim is only an auxiliary rule of statutory
construction. It is NOT of universal application– neither is it
conclusive.
●​ Where a statute appears on its face to limit the operation of its
provisions to particular persons or things by enumerating them,
but no reason exists why other things not so enumerated should
not have been included and manifest injustice will follow by not
so including them, hence the maxim should be invoked.
●​ It cannot be convincingly argued, bayonet is not a bladed,
pointed, or blunt weapon of which outsides of one’s residence is
decreed by PD No. 9 to be illegal.
●​ Court did not apply expression unius est exclusion alterius
because it could lead to absurdity and defeat the legislative
intent
●​ Carrying outside one’s residence of such weapons, which are
less deadly than the bayonet, are prohibited under the law, there
is no logical reason why the bayonet should be exempted.
-​ Example of necessary implication
E. Dissimilum
dissimilis estratio
1.​ Garvida v. Sales
Ruling in relation to Statutory Construction:
●​ SC utilized this maxim to clarify different categories of
candidates should be evaluated according to their qualifications
●​ Court emphasized that the qualifications for candidates are
explicitly defined by law, and individuals n different categories
should not be treated unless expressly stated by legislation
●​ Court carefully examined the statutory language regarding
candidate qualifications, noting that certain qualifications were
specifically enumerated while others were not.
●​ The courts may distinguish when there are facts and
circumstances showing that the legislature intended a distinction
or qualification.
●​ Qualifications of a member and voter in the katipunan ng
kabataan and a candidate for the sangguniang kabataan
F. Casus omissus
1.​ Commission on Audit of the Province of Cebu v. Province of
Cebu
Ruling in relation to Statutory Construction:
●​ Casus omissus pro omisso habendus est: a person, object, or
thing omitted from an enumeration in a statute must be held to
have been omitted intentionally. It is NOT for this Court to supply
such grant of scholarship where the legislature has omitted it.
●​ The court reinforced the idea that any amendments or
expansions to COA’s authority would need to come from
legislative action rather than judicial interpretation
●​ College Scholarship Grants: The Supreme Court noted that
while R.A. No. 5447 included provisions for granting government
scholarships to poor but deserving students, this was omitted in
the relevant sections of the Local Government Code of 1991.
●​ This principle supported the ruling that expenses for college
scholarships could not be charged
G. Ubi lex non
distinguit necnos
distinguere
debemos
1.​ Ramirez v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ Where the law does not distinguish, we should not distinguish
●​ The court held that the nature of the conv ersation is immaterial
to the violation of the statute. What ra 4200 penalizes is the act
of secretly recording (overhearing, intercepting) private
communications
2.​ Dabalos v. Regional Trial Court
Ruling in relation to Statutory Construction:
●​ While it is required that the offender has or had sexual or dating
relationship with the offended woman, for RA 9262 to be
applicable, it is not indispensable that the act of violence be a
consequences of such relationship. Nowhere in the law can
such limitation be inferred.
●​ ​Ubi lex non distinguit nec nos distinguere debemos: “Where the
law does not distinguish, neither should we distinguish.” ,
punishable acts refer to all acts of violence against women with
whom the offender has or had a sexual or dating relationship.
H. Reddendo
singula singulis
1.​ People v. Tamani
Ruling in relation to Statutory Construction:
●​ Words “promulgation, notice, judgement, and order” that
construction is sanction by the rule of reddendo singula singulis:
referring each to each, each phrase or expression to its
appropriate object or let each be put in its proper place, that is,
the words should be taken distributively
2.​ Amadora v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ “Teachers” should apply the words “pupils and students” and
“heads of establishments of arts and trades” to the word
“apprentices”
●​ General rule: if school is academic, teachers shall be held liable
for the acts of their students. Exception: if school; is
non-academic/vocational, the heads are liable.
●​ "Reddendo singula singulis" is a Latin legal maxim that
means "by rendering each in its own specific sense." This
principle is used in statutory interpretation to emphasize the
importance of construing words or phrases in accordance with
their specific context or meaning within a statute. It directs that
each term or phrase should be understood and applied
according to its particular and distinct definition or usage as
intended by the legislature, avoiding confusion or
misinterpretation.
●​ Dahil may words na teachers and students, may intention ung
congress to include them. Not only trade school.
I.​
Doctrine of
necessary
implication
1.​ Chua v. CSC
Ruling in relation to Statutory Construction:
●​ SC applied the doctrine to interpret the coverage of the statute
broadly enough to include employees like Chua, who had served
continuously in various government projects for an extended
period.
●​ Court reasoned that Chua’s employment was technically
classified as co-terminious, the intent behind the legislation was
to provide benefits for government employees whose positions
might not fit traditional classifications but who nonetheless
contributed significantly to public service
●​ Excluding Chua would violate the equal protection clause of the
constitution.
●​ The court ruled in favor of Lydia Chua, holding that the denial of
her application for early retirement benefits under R.A. 6683 by
NIA and CSC was unreasonable, unjustified, and oppressive.
●​ The court highlighted that R.A. 6683 covers regular, temporary,
casual, and emergency employees with at least two consecutive
years of government service, excluding only uniformed
personnel of the AFP and PC-INP. Chua's employment history
showed continuous government service despite being
categorized as a co-terminous employee with the NIA project.
●​ The doctrine of necessary implication is a legal principle that
states that when a law expressly grants a power or imposes a
duty, it also implies by necessity the authority to use reasonable
means to carry out that power or duty. This doctrine ensures that
the explicit provisions of the law are effectively implement.
●​ Cannot expect our legislature to enumerate everything. So take
a look at the statutory intention. Kalokohan pag di sinama.
2.​ Primero v. Court of Appeals
Ruling in relation to Statutory Construction:
●​ Where a statute appears on its face to limit the operation of its
provisions to particular persons or things by enumerating them,
but no reason exists why other ... things not so enumerated
should not have been included, and manifest injustice will follow
by not so including them, the maxim expressio unius est
exclusio alterius should not be invoked
●​ It cannot be convincingly argued that a bayonet is not a bladed,
pointed or blunt weapon. Therefore, there is no logical reason
why the bayonet should be exempted from the prohibition.
J. Doctrine of Last
antecedent
1.​ Florentino v. PNB
Ruling in relation to Statutory Construction:
●​ Whether the clause “who may be willing to accept the same for
settlement” applied only to the last antecedent– specifically, “any
citizen of the Philippines, or any association or corporation
organized under the laws of the Philippines”-- or if it extended to
all preceding antecedents, including government entities.
●​ Court ruled that the qualifying clause applied only to the last
antecedent meaning that while private entities could choose to
accept backpay certificates, govt entities were mandated to do
so.
●​ The legal provision in question is section 2 of Republic Act No.
879, which discusses the settlement of debts using backpay
certificates.
●​ Grammatically, the qualifying clause refers only to the last
antecedent; that is, "any citizen of the Philippines or any
association or corporation organized under the laws of the
Philippines." It should be noted that there is a comma before
the words or to any citizen, etc.," which separates said phrase
from the preceding ones.
●​ The Secretary of Justice, in his Opinion No. 228, series of
1948, held that the phrase "who may be willing to accept the
same for such settlement" qualifies only its immediate
antecedent and does not apply to the Government or its
agencies.
●​ Interpreting the clause to apply to all antecedents would render
the section unconstitutional by forcing private entities to accept
backpay certificates, thus impairing the obligation of contracts.
●​ The Doctrine of Last Antecedent is a principle of statutory
interpretation stating that qualifying words, phrases, or clauses
are to be applied to the words or phrases immediately preceding
them, unless the context or evident meaning of the statute
requires a different interpretation.
●​ Dapat may choice kami to refuse backpay, Sabi ng court hindi,
kasi it only applies to private corporation.
K. Provisos
1.​ Fernandez v. NLRC
Ruling in relation to Statutory Construction:
●​ 2nd paragraph of article 80 = Proviso. Only applies
●​ SC examined the relevant labor law provisions containing
provisos– clauses that qualify or limit the general provisions
preceding them. The court emphasized that these provisos must
be interpreted in light of their specific context and legislative
intent.
●​ They should be construed in such a way as to give effect to both
the general provisions and the qualifications introduced by the
proviso. That means that when interpreting, courts must
consider how the proviso modifies or clarifies the preceding
provisions.
●​ Court ruled that in cases where statute includes a proviso, it is
essential to read it in conjunction with the main provision it
modifies.
●​ Policy Instruction No. 20: Applies to the construction industry;
project employees are not entitled to termination pay upon
project completion.
●​ Article 280 of the Labor Code: Proviso deeming regular
employees does not apply to project employees. Petitioner
misinterpreted the provision, which explicitly excludes project
employment.
●​ A proviso is a clause in a statute, contract, or legal document
that stipulates a condition or a specific limitation. It usually
begins with the word "provided" and qualifies the general terms
of the document.
I.​
Technical
words with
technical
meaning
M. Progressive
Construction
1.​ Manila Herald Publishing v. Ramos
Ruling in relation to Statutory Construction:
●​ terms like "intervene" and "independent action" have particular
implications under procedural rules that must be respected to
ensure proper application of the law.
●​ By applying the principle regarding technical meanings, the
Court ensured that its interpretation aligned with established
legal definitions, thereby avoiding confusion or misapplication of
procedural rights.
●​ In legal interpretation, technical words and technical
meanings refer to terms that have a specific, established
meaning within a particular field or profession. When such words
are used in statutes, contracts, or legal documents, they are
presumed to carry their specialized meaning.
1.​ Diuquino v. Araneta
Ruling in relation to Statutory Construction:
●​ The Supreme Court applied the doctrine of progressive
construction to interpret Article 1903 in light of contemporary
societal conditions and the increasing prevalence of automobile
accidents.
●​ The Court recognized that while Article 1903 specifies liability for
negligent acts within certain established relationships (such as
employer-employee), it also allows for an evolving
understanding of these relationships as society changes.
●​ Progressive Construction refers to a method of statutory
interpretation where the language of the law is interpreted in a
dynamic and evolving manner, taking into account contemporary
conditions and societal changes. This approach aims to adapt
the application of the law to current realities rather than sticking
rigidly to the original wording or intent.
N.
Conjunctive/disjunc
tive words
1.​ Solanda v. CA
Ruling in relation to Statutory Construction:
●​ The aforecited whereas clauses express a clear intent to limit
the operation of PD 1517 to specific areas declared to be
located in both an APD and a ULRZ. The conjunctive and in the
last sentence of the quoted provision confirms this intention. And
in statutory construction implies conjunction, joinder or union.
As understood from the common and usual meaning of the
conjunction and, the provision of PD 1517 apply only to area
declared to be located within both an APD and ULRZ.
●​ Statutory Right of First Refusal: The Supreme Court held that
Manlutac did not have a statutory right of first refusal under PD
1517. This was because the disputed property did not fall within
an APD and ULRZ designated by Proclamation No. 1967. The
Court emphasized that statutory rights are contingent upon
specific geographic designations, which were absent in this case
●​ The second issue concerns whether Luis Manlutac had a
statutory right of first refusal to purchase the property under PD
1517. This law grants tenants in certain urban reform areas the
right to buy the land they occupy if it falls within specified
development zones. The Supreme Court found that the property
in question did not meet the criteria outlined in Proclamation No.
1967, which defines these zones. Therefore, Manlutac did not
have a legal basis to claim a preemptive right to purchase the
property. The Court clarified that the right only applies if the land
is within designated urban reform zones, which was not the case
here.
●​ In conclusion, the Supreme Court upheld the lower court's
decision to eject Manlutac from the property owned by Solanda
Enterprises, affirming that he had no legal right to remain on the
premises beyond the terms of his lease. This decision focused
on possession rather than ownership, leaving the ownership
dispute to be resolved separately in another legal proceeding.
2.​ Pimentel v. COMELEC
Ruling in relation to Statutory Construction:
●​ A rule in statutory construction is that the word “or” is disjunctive
term signifying dissociation and independence of one thing from
other things enumerated unless the context requires a different
interpretation.In criminal and penal statues, like Section 27(b) of
R.A. 6646, the word “and” cannot be read “or,” and conversely,
as the rule of strict construction apply,except when the spirit and
reason of the law require it.
●​ From a reading of Section 27(b) of R.A. 6646 in its entire
context, we cannot but conclude that giving a non-disjunctive
meaning to the word “or” is not warranted.
●​ (b) Any member of the board of election inspector or board of
canvassers who tampers, increases, or decreases the votes
received by a candidate in any election or any member of the
board, who refuses, after proper verification and hearing, to
credit the correct votes or deduct such tampered votes.
O. Mandatory v.
Permissive words
1.​ Director of Lands v. CA
Ruling in relation to Statutory Construction:
●​ The law used the term “shall” in prescribing the work to be done
by the Commissioner of Land Registration upon the latter’s
receipt of the court order setting the time for initial hearing. The
said word denotes an imperative and thus indicates the
mandatory character of a statute.[15] While concededly such
literal mandate is not an absolute rule in statutory construction,
as its import ultimately depends upon its context in the entire
provision, we hold that in the present case the term must be
understood in its normal mandatory meaning.
●​ Time and again, this Court has declared that where the law
speaks in clear and categorical language, there is no room for
interpretation, vacillation or equivocation; there is room only for
application.
●​ The Supreme Court ruled in favor of the Director of Lands,
asserting that newspaper publication was indeed mandatory.
Section 23 of PD 1529 explicitly requires publication in both the
Official Gazette and in a newspaper of general circulation. While
the publication in the Official Gazette confers jurisdiction upon
the court, the additional publication in a newspaper serves the
purpose of providing notice to interested parties and ensuring
procedural due process.
●​ In statutory interpretation, mandatory words (such as "shall" or
"must") indicate an obligation or requirement, implying that the
action is compulsory. Conversely, permissive words (such as
"may" or "can") suggest discretion or choice, implying that the
action is optional.
2.​ Lokin v. Commission on Elections
Ruling in relation to Statutory Construction:
●​ The use of mandatory words such as "shall" indicated that
parties are required to submit a definitive list without alterations
after submission, while permissive words like "may" would
suggest optional actions.
●​ The Supreme Court examined the language used in Section 8 of
Republic Act No. 7941 (the Party-List System Act), which stated
that "each registered party... shall submit... a list of names, not
less than five (5), from which party-list representatives shall be
chosen in case it obtains the required number of votes.”
IV. Interpreting
Conflicting
provisions
P. Pari Materia
Q. Special v.
General Law
1.​ PEZA v. Green Asia
Ruling in relation to Statutory Construction:
●​ The Supreme Court emphasized that when interpreting laws,
particularly those related to public contracts and price
adjustments, it is essential to read related statutes in conjunction
with one another. This approach ensures that legislative intent is
preserved and that provisions are applied consistently.
●​ The Court noted that Presidential Decree No. 1594 and
Presidential Decree No. 454 both pertain to public works and
contract management, and thus should be interpreted together.
PD 454 provides guidelines for price adjustments in government
contracts, which are relevant when considering claims for price.
●​ By applying the doctrine of pari materia, the Court highlighted
that the relationship between PD 1594 and PD 454 should lead
to a more comprehensive understanding of how price
adjustments should be handled in public contracts.
2.​ Corona v. CA
Ruling in relation to Statutory Construction:
●​ these laws should be construed in relation to one another to
ensure consistency and harmony in application.
●​ The Court found that relevant provisions from different laws
should be read together because they addressed similar issues
regarding jurisdiction and enforcement, thereby clarifying how
they interact with each other.
●​ it could harmonize conflicting provisions and establish a
clear understanding of the jurisdictional boundaries
between different courts.
●​ The Court examined the provisions of Executive Orders Nos. 1,
2, and 14, which created the PCGG and outlined its powers.
These statutes were interpreted in pari materia to determine the
extent of the PCGG's authority.
●​ the Court upheld the intent of the legislative and executive
branches in establishing a mechanism for recovering ill-gotten
wealth while protecting individual rights.
1.​ LLDA v. CA
Ruling in relation to Statutory Construction:
●​ It has to be conceded that the charter of the Laguna Lake
Development Authority constitutes a special law. Republic Act
No. 7160, the Local Government Code of 1991, is a general law.
It is basic in statutory construction that the enactment of a later
legislation which is a general law cannot be construed to have
repealed a special law. It is a well-settled rule in this jurisdiction
that "a special statute, provided for a particular case or class of
cases, is not repealed by a subsequent statute, general in its
terms, provisions and application, unless the intent to repeal or
alter is manifest, although the terms of the general law are broad
enough to include the cases embraced in the special law."
●​ Where there is a conflict between a general law and a special
statute, the special statute should prevail since it evinces the
legislative intent more clearly than the general statute. The
special law is to be taken as an exception to the general law in
the absence of special circumstances forcing a contrary
conclusion. This is because implied repeals are not favored and
as much as possible, effect must be given to all enactments of
the legislature. A special law cannot be repealed, amended or
altered by a subsequent general law by mere implication.
●​ RA 4850 is a special law, while the Local Government Code of
1991 is a general law. A special law is not repealed by a general
law unless explicitly stated. The Local Government Code does
not expressly repeal the LLDA's authority.
●​ The local governments’ authority under the Local Government
Code is primarily for revenue generation, whereas the LLDA's
powers are regulatory, focusing on environmental protection and
resource management.
R. Substantive v.
Procedural Law
1.​ Primicias v. Ocampo
Ruling in relation to Statutory Construction:
●​ We have already pointed out that the basic provisions on the
matter partake of the nature of substantive law and as such they
were left intact by the Supreme Court. The corollary to this
conclusion is that this remedy may be invoked out only in Manila
but in all other places where it existed prior to the promulgation
of the Rules of Court. This is true in civil cases.
●​ The Supreme Court ruled that the right to a trial with the aid of
assessors is indeed a substantive right. The Court defined
substantive law as that which creates, defines, or regulates
rights concerning life, liberty, or property, while procedural law
prescribes the methods by which those rights may be enforced
in courts.
●​ The ruling emphasized that substantive rights are essential to a
party's legal standing and cannot be altered or diminished by
procedural rules established by courts. In this context, the right
to have assessors present during trial is integral to ensuring a
fair assessment of facts in cases where it is invoked.
2.​ Fabian v. Desierto
Ruling in relation to Statutory Construction:
●​ The Supreme Court emphasized the importance of
distinguishing between substantive and procedural laws in its
ruling. Substantive law defines rights and duties, while
procedural law outlines the methods and processes for enforcing
those rights and duties.
●​ In this context, the Court ruled that the right to a fair hearing is a
substantive right that cannot be disregarded by procedural rules.
The absence of a proper hearing constituted a violation of
Fabian's substantive rights.
3.​ PNB v. Independent Planter’s
Ruling in relation to Statutory Construction:
●​ The issue at hand was whether a procedural rule could limit the
bank's rights under substantive law regarding its ability to
proceed against any one or all of the solidary debtors.
●​ The Supreme Court clarified that substantive law defines rights
and obligations, while procedural law outlines the methods by
which those rights are enforced. In this case, Article 1216 of the
New Civil Code establishes the bank's right to proceed against
any solidary debtor.
●​ The Court emphasized that procedural rules cannot diminish or
alter substantive rights. Specifically, it ruled that Section 6, Rule
86 of the Revised Rules of Court, which set forth procedures for
enforcing claims against an estate, should not be interpreted to
restrict the bank's substantive right to pursue any solidary
debtor.
●​ The ruling highlighted that if procedural rules were allowed to
override substantive rights, it would effectively repeal or diminish
those rights without legislative intent. The Court stated that such
a construction is not permissible under established legal
principles.
S. Earlier law v.
later law/
amendment and
repeal
1.​ Mecano v. COA
Ruling in relation to Statutory Construction:
●​ The petitioner, Mecano, sought reimbursement for expenses
related to sickness incurred while performing his duties as a
government employee, claiming entitlement under Section 699
of the Revised Administrative Code (RAC). The COA denied his
claim, asserting that Section 699 had been repealed by the
Administrative Code of 1987.
●​ The Supreme Court emphasized that repeals by implication are
not favored in statutory construction. The presumption is against
inconsistency and repugnancy; it is assumed that the legislature
is aware of existing laws and does not intend to enact conflicting
statutes.
●​ The Court identified two categories for determining implied
repeal:
○​ Irreconcilable Conflict: This occurs when two statutes
cover the same subject matter and are so inconsistent
that they cannot both be enforced.
○​ Complete Coverage: This occurs when a later act is
intended to cover the entire subject matter of an earlier
law and is clearly meant as a substitute.
●​ The Court ruled that there was no irreconcilable conflict between
Section 699 of the RAC and the provisions of the Administrative
Code because the latter did not address sickness benefits,
which were specifically covered by the former.
●​ It concluded that since Section 699 was not restated or
re-enacted in the Administrative Code, it remained operative.
The general repealing clause in the Administrative Code was
insufficient to imply repeal because it did not specifically identify
which provisions were being repealed.
●​ The ruling underscored that legislative intent must be clear when
determining whether a new law has repealed an earlier one. The
Court noted that if a later statute does not explicitly state an
intention to repeal or does not cover the same subject matter
comprehensively, then the earlier law remains in effect.
●​ This interpretation aligns with established principles in statutory
construction, emphasizing that special laws (like those providing
specific benefits) should prevail over general laws unless
explicitly stated otherwise.
T. Pari materia
review
1.​ Zameco II v. CASCONA
Ruling in relation to Statutory Construction:
●​ The Supreme Court emphasized that laws concerning electric
cooperatives must be interpreted in conjunction with one another
to understand their implications fully. Specifically, the Court
analyzed several statutes, including R.A. No. 6939 (Cooperative
Code of 1990), R.A. No. 9136 (EPIRA), R.A. No. 9520
(Philippine Cooperative Code of 2008), and R.A. No. 10531
(National Electrification Administration Reform Act of 2013).
●​ The Court ruled that ZAMECO II remained under the jurisdiction
of the National Electrification Administration (NEA) and not the
CDA, despite its registration with the latter. It concluded that the
CDA's issuance of a certificate of registration did not divest NEA
of its jurisdiction because ZAMECO II had not complied with
statutory requirements for conversion as mandated by EPIRA.
●​ The ruling underscored that when interpreting laws that govern
similar subjects, courts must consider how these laws interact
and complement each other.