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INTRINSIC AIDS

Internal or within
Aids within the statute
Resorted to only if there is ambiguity
Parts of statute, title, preamble, body, chapter & section headings,
punctuation & interpretation clause

Title and text of Law is valuable intrinsic aid in determining legislative


intent

Subtitle of Statute
Jai alai title of law
Miriam Defensor, et al. vs. COMELEC subtitle
Eugenio preamble (Delta Village)

EXTRINSIC AIDS

Existing aids from outside sources


Resorted to only after exhausting all available intrinsic aids and ambiguity
remains
Extrinsic aids:
1. History of enactment
2. Opinions & rulings of government officials called to execute or
implement administrative laws
3. Contemporaneous construction by executive officers
4. Actual proceedings of legislative body
5. Individual statements by members of congress
6. Author of the law
7. Explanatory note of the bill

Printed pages or published ACT and extrinsic matters such as history of


enactment, reasons for passage, and purposes to be accomplished

COMISSIONER OF CUSTOMS vs. ESSO STANDARD EASTERN, INC

RA 387 During 5 years following granting of concession, the concessionaire


may import free of customs duty, all equipment, material, instruments,
supplies, and accessories
RA 1394 impose special import tax on imported goods, repealed 6 prior
statutes
Collector of Customs held ESSO subject to payment
Court of Tax Appeals- reversed decision; ordered refund of P775.62

Issue: Whether exemption enjoyed by ESSO from RA 387 should embrace special
import tax RA 1394

Intent of RA 387 encourage exploitation and development of petroleum


resources of the country
RA 1394 unmistakably repealing 6 prior statutes; spared RA 387
Congress saw fit to preserve privileges under RA 387, Petroleum Act, in order
to keep the door open to exploitation & development of petroleum\
PETITION DENIED

Opinions and rulings of officials of the government called upon to execute


or implement administrative laws command much respect and weight

VERA VS CUEVAS, INSTITUTE OF EVAPORATED MILK MANUFACTURERS

Commissioner of Internal Revenue required INSTITUTE to withdraw from


market all filled milk products without inscription
SEC 169 Inscription to be placed on skimmed milk This milk is not
suitable for nourishment for infants less than one year of age
Court restrained IR Commissioner from requiring INSTITUTE to print on labels
of their filled milk

HELD

Skimmed milk fatty part has been removed


Filled milk fatty part substituted with refined coconut oil, corn oil, both
Board of Food Inspection in 1961 rendered opinion that filled milk does
not come within purview of Sec 169
DECISION AFFIRMED

Contemporaneous construction placed upon statute by executive officers


charged with implementing and enforcing the provisions of the statutes
PAFLU VS BUREAU OF LABOR RELATIONS, NAFLU

Certification election NAFLU 429 votes vs PAFLU 414 votes


IRR of present Labor code majority of valid votes cast suffices for
victorious labor union as sole and exclusive bargaining agent
PAFLU contends spoiled ballots should be counted in determining valid
votes cast (doctrine in Allied workers association vs CIR)

HELD

doctrine arose during period when Industrial Peace Act was in effect and not
present law
IRR of Labor Code issued by Secretary Blas Ople of department of Labor
(present labor code)
PETITION DISMISSED

Courts may avail themselves of the actual proceedings of legislative body


to assist in determining construction of statute
DEVILLA vs CA

De Villa charged with violation of BP Blg 22 Bouncing checks law


De Villa argues check was drawn against dollar account with foreign bank

HELD

Intention of lawmakers is to apply law to whatever currency


Discussion
o Mr. Tupay: any check may be involved like U.S. dollar checks?
o Mr. Mendoza: The bill refers to any check in whatever currency
PETITION DISMISSED

In case of doubt as to what provision in statute means, meaning put to


provisions during legislative deliberations may be adopted
NATIONAL POLICE COMMISSION vs JUDGE DE GUZMAN

RA 6975, Sec. 39 - Compulsory retirement of PNP officers 56 years old


Petitioners sent notice to private respondents (PC) who reached 56
PC asked for injunction because Sec 39 cannot apply to them since they are
covered by Sec 89
Transition period 4 years INP
RTC ruled in favour of Private respondents

ISSUE: W/N RA 6975 distinguishes INP from PC


HELD

INP not the same as PC


Records
o Sen Maceda: PC walang mawawala sakanila, 56 ang retirement age
nila talaga.

Individual Statements by members of Congress on the floor doesnt


necessarily reflect legislative intent
CASCO PHILIPPINE CHEMICAL vs HON GIMENEZ

Casco bought foreign exchange for importation of urea and formaldehyde


Casco sought refund of P33,765.41 and P6,345.72 upon Resolution 1529 of
Monetary Board of Central Bank declaring exemption from fee
Auditor of the Bank refused to approve vouchers not in accordance with RA
2609

ISSUE: W/N Urea and formaldehyde are exempt from margin fee
HELD

National Institute of S&T says UF is different from U&F


Casco cited statements made on the floor