Customs vs CTA

Customs insists that port of Kiwalan should be

subject to berthing fees however, it is not listed
as National Ports. whatever is omitted is
understood to be excluded
Conte vs CA
SSS had no authority to maintain and
implement such retirement plan. It cannot
legislate or amend laws. SSS resolution 56 is
declared illegal due to its conflict between
RA1616 In case of conflict between a
statute and Admin Order, former shall
prevail
DIU vs CA
The case was filed when PD 1508 was still in
force. Later, it was repealed by Local Govt
Code of 1991. Latter law will prevail
retroactively in the case Procedural laws are
retrospective = Statues regulating procedure
in courts are applicable to actions pending
and undetermined at the time of their
passage
Erectors vs NLRC
While petitioners case was still in conciliation
stage, EO 797 creating POEA was established
creating jurisdiction over employee-employer
relationship. EO797 is not curative statute so it
should not affect cases filed prior to its
effectivity. Laws should only be applied
prospectively unless the contrary is
expressly provided or is necessarily
implied from the language used
Frivaldo vs COMELEC
SC held that PD725 is curative in nature which
provided that the repatriation of the petitioner
retroacted (although not expressly stated) to
the filing of his citizenship reacquisition.
Implied repeal is allowed if the 2 laws are
clearly repugnant and patently inconsistent
that they cant co-exist"

Gloria vs CA
Civil Service Act 1959 provided payment of
salaries in case of exoneration. Law was
revised 1975 deleting payment during
suspension. Amendment by deletion of
certain words in a statute indicates
CLEARLY legislatures intent to change the
meaning of the statute"
IBP vs Zamora
The intent of the constitution is exactly what its
letter says, that the power to calling out its
marines is fully in discretion of the president.
Where the terms are expressly limited,
interpretation cant be extended to other
matters
Convention Proceedings - intent of people
through discussions of their
representatives < Legislative Proceedings intent of the legislature
Ajero vs CA
CA found that holographic will failed to meet
the requirements for its validity but not its
probate. Such failure does not render the
whole testament void. General rule: laws on
this subject should be interpreted to attain
primordial ends and guaranty their truth
and authenticity. Exception: An
interpretation already given assures such
ends, any other interpretation whatsoever,
that adds nothing but demands more
requisites entirely unnecessary must be
disregarded"
Amatan vs Aujero
The death of an individual should not be
ignored of a more expedient plea of either
attempted of frustrated homicide. When a
provision is silent, judges ought to invoke
a solution responsive to urge of
conscience. However, literal application of
law can lead to injustice

Bautista vs SB
The use of the disjunctive term or between
the phrases by causing any undue injury to
any party, including the government and by
giving any private party unwarranted benefits,
advantage or preference connotes that either
act qualifies as a violation and accused may
be charged under either mode or under
both. Language of statute"
Catubay vs NLRC
No justifiable reason was put forth by the
private respondents for their late filing of the
required bond. The intention of the lawmakers
to make a bond an indispensable requisite for
the perfection of an appeal by
employer Language of the statute"
Claudio vs Comelec
?
Carcellar vs CA
The delay is not substantial and did not
amount to breach the intention of the parties
when they executed the lease contract with
option to purchase. Analysis and
construction should not be limited to the
words used in the contract, as they may
not accurately reflect the parties' true
intent. The reasonableness of the result
obtained, after said analysis, ought
likewise to be carefully considered
Enrique vs CA
Petitioners claim that PD807 Sec37 has been
impliedly repealed by PD 1409 where Merit
systems Board have jurisdiction on the case.
However, Civil Service Commission remains
final appellate body as provided in PD1409
Sec8. Repeals by implication are not
favored. Great weight must be accorded to
the interpretation of a statute by govt
agency called upon to implement the
same

Francisco vs Boiser
Difference of Art 1524 from 1623 is that the
former did not specify who must give the
notice, whereas the present one expressly
says the notice must be given by the
vendor If the law is clear, theres no room
for interpretation
Valenzuela vs Vallarta
?
Kilosbayan vs Morato
The SCs interpretation of RA1169 (power of
PCSO to enter into any cotract of
collaboration, association, and joint venture) in
the earlier Kilosbayan case must be
reexamined. Interpreting the law, author >
Legislatures proceedings > Convention
Proceedings / Law of the case doctrine is
not applicable since the case is not a
continuation of the first case

LLDA
There was no intent on the part of legislatures
to repeal RA 4850 and its amendments by RA
7160 (special law) thus, jurisdiction over
Laguna Lake belongs to Laguna Lake
Authority. Repeal laws should be made
clear and expressed. Enactment of a later
general law cannot be construed to have
repealed a special law unless the intent to
repeal is clearly manifested. General Law <
Special Law
Landbank vs CA
It is very clear that the law explicitly indicated
that deposit bust be made only in cash or in
LBP bonds and not any other form. IF theres
an intention, it could have been expressly
stated or words are implying the same. No
ambiguity in the law to warrant an
expanded construction of the
form deposit"

Melendres vs COMELEC
The payment of the filling fee is an
administrative procedural matter, proceeding
as it does from an administrative body. The
interpretation of an administrative govt
agency, which is tasked to implement a
statute, is accorded great respect and
ordinary controls the construction of the
courts to determine what the law means
NPC vs Province
Repeals by implication are not favored
unless its intention is manifested. If they
can be reconciled, the later act will not
operate as a repeal of the earlier
Pahilan vs Tabalba
His claim should be immediately cleared for
the benefit of the winner and public interest,
which can only be achieved by brushing aside
technicalities of procedure which protract and
delay the trial of an ordinary action General
rule: statutes providing for election
contests are to be liberally interpret to the
end that the will of the people in the choice
of public officers may not be defeated by
mere technical objections
Evangelista vs People
Public officer should have acted by causing
any undue injury to any party, including the
govt, or by giving any private party
unwarranted benefits in the discharge of his
functions The use of or connotes that an
accused may be charged under either
mode or both
People vs Quijada
A. Homicide or murder w/o unlicensed firearm
cant be the primary purpose of the offender B.
Homicide or murder with unlicensed firearm is
the primary objective. With the use of have
the same meaning as well as as a result or on
the occasion of, a meaning which is neither
born out by the letter of the law nor supported

by its intent. If a statute is clear, plain, and

free from ambiguity, it must be given its
literal meaning and applied without
attempted interpretation, leaving the court
no room for any extended ratiocination or
rationalization of the law.
Pimentel vs Aguirre
The provision in the Local Govt Code providing
for such release uses the word shall and as a
rule, a word of command thus, must be given
compulsory meaning. Language of the law
PNOC vs CA
Price quotations issued personally to a person
who requested for them from dealers are not
commercial lists. Ejusdem Generis (Of the
same kind or nature) A rule of
interpretation that where a class of things
is followed by general wording that is not
itself expansive, the general wording is
usually restricted things of the same type
as the listed items.
Republic vs CA
Administrative issuances seeking to carry
effect an act of Congress must be in harmony
with the provisions of the law, it cannot modify
nor supplant the same Construction of
Law
Romualdez vs COMELEC
Petitioner cant be adjudged by a different
constitution, and the worst way to interpret the
constitutuion is to inject in its interpretation,
bile and bitterness. The difference between a
mandatory and directory provision is often
made on grounds of necessity. Statute
requiring rendition of judgment within a
specified time is generaly interpreted to be
merely directory

St. Martin vs NLRC

A review of the legislative records on the
antecedents of RA7902 persuades the court
that there may have beed an oversight in the
course of the deliberations and the said act or
imprecision in the terminology used therein.
The use of word appeal could have been
Lapsus Plumae because appeals by certiorari
is addressed to the appellate courts. Thus, it is
interpreted to mean and refer to petitions for
certiorari.Language and terms used
Tan vs People
Court expressly tuled that Lumber is included
in the term Timber. Possession of timber
without required legal docs concerned the
law. In the absence of legislative intent to
the contrary, words and phrases used in a
statute should be given their plain usage
meaning
Univ of Physician vs CA
There is no dispute that under the express
terms of the Lease agreement, petitioner was
granted an option to extend the contract.
However, such option to extend must not be
read in isolation from the rest of terms of the
provision. The use of may be
extended connotes possibility and not
certainty thus, did not portray mutual
option. Language and terms used
Aguetas vs CA
Sectoin 231 of Omnibus Election Code was
not expressly repealed by RA 7166. If repeal
of specific law is intended, the proper step
is to express it or it must
be irreconcilably inconsistent and
repugnant and cant stand together with the
existing law
Allied Banking vs CA
An express agreement which gives the lessee
the sole option to renew the lease is frequent
and subject to statutory restrictions, valid, and

binding on parties.Language - As in a
statute no word, clause, sentence,
provision or part of a contract shall be
considered meaningless. A construction
which will render every word operative is to
be preferred over that which would make
some words idle and nugatory.
ADDITIONAL CASES
Cooperative Development Authority vs.
Dolefil Agrarian Reform Beneficiaries
Cooperative, Inc.
When the law speaks in clear and categorical
language, there is no room for interpretation,
vacillation or equivocationthere is only room
for application; It can be gleaned from Section
3 of R.A. No. 6939 that the authority of the
CDA is to discharge purely administrative
functions which consist of policy-making,
registration, fiscal and technical assistance to
cooperatives and implementation of
cooperative laws.It is a fundamental rule in
statutory construction that when the law
speaks in clear and categorical language,
there is no room for interpretation, vacillation
or equivocationthere is only room for
application. It can be gleaned from the abovequoted provision of R.A. No. 6939 that the
authority of the CDA is to discharge purely
administrative functions which consist of
policy-making, registration, fiscal and technical
assistance to cooperatives and implementation
of cooperative laws. Nowhere in the said law
can it be found any express grant to the CDA
of authority to adjudicate cooperative disputes.
At most, Section 8 of the same law provides
that upon request of either or both parties, the
Authority shall mediate and conciliate disputes
with a cooperative or between cooperatives
however, with a restriction that if no mediation
or conciliation succeeds within three (3)
months from request thereof, a certificate of
non-resolution shall be issued by the
commission prior to the filing of appropriate
action before the proper courts. Being an
administrative agency, the CDA has only such
powers as are expressly granted to it by law
and those which are necessarily implied in the
exercise thereof.

National Federation of Labor vs. Eisma

The Labor Arbiter rather than a regular court
has jurisdiction to entertain, a complaint for

damages by an employer against his

employees arising from picketing that
accompanied a strike.Article 217 is to be
applied the way it is worded. The exclusive
original jurisdiction of a labor arbiter is therein
provided for explicitly. It means, it can only
mean, that a court of first instance judge then,
a regional trial court judge now, certainly acts
beyond the scope of the authority conferred on
him by law when he entertained the suit for

SIlva vs Cabrera

damages, arising from picketing that

accompanied a strike. That was squarely
within the express terms of the law. Any
deviation cannot therefore be tolerated. So it
has been the constant ruling of this Court even
prior to Lizarraga Hermanos v. Yap Tico, a
1913 decision. The ringing words of the
ponencia of Justice Moreland still call for
obedience. Thus, The first and fundamental
duty of courts, in our judgment, is to apply the
law. Construction and interpretation come only
after it has been demonstrated that application
is impossible or inadequate without them. It is
so even after the lapse of sixty years.

could be convinced of the necessity of

amending the law.

The issuance of Presidential Decree No. 1691

and the enactment of Batas Pambansa Blg.
130, made clear that the exclusive and original
jurisdiction for damages would once again be
vested in labor arbiters. It can be affirmed that
even if they were not that explicit, history has
vindicated the view that in the appraisal of
what was referred to by Philippine American
Management & Financing Co., Inc. v.
Management & Supervisors Association of the
Philippine-American Management & Financing
Co., Inc. as the rather thorny question as to
where in labor matters the dividing line is to be
drawn between the power lodged in an
administrative body and a court, the
unmistakable trend has been to refer it to the
former. Thus: Increasingly, this Court has
been committed to the view that unless the law
speaks clearly and unequivocally, the choice
should fall on [an administrative agency].
Certainly, the present Labor Code is even
more committed to the view that on policy
grounds, and equally so in the interest of
greater promptness in the disposition of labor
matters, a court is spared the often onerous
task of determining what essentially is a
factual matter, namely, the damages that may
be incurred by either labor or management as
a result of disputes or controversies arising
from employer-employee relations.

STATUTORY CONSTRUCTION; WHERE

PROVISION OF LAW is CLEAR
COMPLIANCE THEREWITH is ESSENTIAL.
Where the law is clear, neither this court nor
the commission may on grounds of
convenience, expediency or prompt dispatch
of cases, disregard the law or circumvent the
same. The remedy lies with the legislature if it

Hermanos vs Yap Tico

THE DEMURRER, ITS PURPOSE AND
SUFFICIENCY."The demurrer must distinctly
specify the grounds upon which any of the
objections to the complaint, or to any of the
causes of action therein stated, are
taken." (Sec. 91, Code of Civil Procedure.)
When a demurrer is interposed to a complaint,
whether upon one ground or upon another, it
should set f orth distinctly the ground upon
which the objection is based. It cannot be
couched simply in the language of the Code; it
must set out clearly the grounds upon which
that language is founded. It is not f fair to the
plaintiff to interpose simply an objection that
the complaint does not state facts sufficient to
constitute a cause of action, nor is it fair to the
court. Neither the plaintiff nor the court should
be left to make what may possibly be a long
and tiresome examination of the complaint.
The real reasons for the objection should be
pointed out so that all may see. The demurrer
was not invented to make useless work for the
court or to deceive or delude a plaintiff; its
purpose is to clarify all ambiguities, to make
certain all indefinite assertions, to bring the
plaintiff to a clear expression of his precise
grievance, to aid in arriving at the real issue, to
promote understanding, and to prevent
surprise.
Caltex (Philippines), Inc. vs. Palomar
Statutes; Construction defined.Construction
is 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, where that intention is
rendered doubtful, amongst others, by reason
of the fact that the given case is not explicitly
provided for in the law (Black, Interpretation of
Laws, p. 1). In the present case, the question
of whether or not the scheme proposed by the
appellee is within the coverage of the

prohibitive provisions of the Postal Law

inescapably requires an inquiry into the
intended meaning of the words used therein.
This is as much a question of construction or
interpretation as any other.

disqualified to adopt as they have legitimate

grandchildren, the petitioners herein. But,
when the Civil Code of the Philippines was
adopted, the word descendants was changed
to children, in paragraph (1) of Article 335.

Weight of judicial decisions.In this

jurisdiction, judicial decisions assume the

Southern Cross Cement Corporation vs.

Philippine Cement Manufacturers
Corporation

same authority as the statute itself and, until'

authoritatively abandoned, necessarily
become, to the extent that they are applicable,
the criteria which must control the actuations
not only of those called upon to abide thereby
but also of those in duty-bound to enforce
obedience thereto.
Term "gift enterprise" is used in association
with word "lottery"In the Postal Law the term
"gift enterprise" is used in association with the
word "lottery." Con-sonant to the well-known
principle of legal hermeneutics noscitur a
sociis, it is only logical that the term be
accorded no other meaning then that which is
consistent with the nature of the word
associated therewith. Hence, if lottery is
prohibited only if it involves a consideration, so
also must the term "gift enterprise" be so
construed. Significantly, there is not the
slightest indicium in the law of any intent to
eliminate the element of consideration from the
"gift enterprise therein included.
Daoang vs. Municipal Judge of San
Nicolas, Ilocos Norte
Rule that a statute clear and unambiguous on
its face need not be interpreted.Well known
is the rule of statutory construction to the effect
that a statute clear and unambiguous on its
face need not be interpreted; stated otherwise,
the rule is that only statutes with an ambiguous
or doubtful meaning may be the subject of
statutory construction.
In enacting the Civil Code, the legislator
obviously intended that only those persons
who have certain classes of children are
disqualified to adopt.Besides, it appears that
the legislator, in enacting the Civil Code of the
Philippines, obviously intended that only those
persons who have certain classes of children,
are disqualified to adopt. The Civil Code of
Spain, which was once in force in the
Philippines, and which served as the pattern
for the Civil Code of the Philippines, in its
Article 174. disqualified persons who have
legitimate or legitimated descendants from
adopting. Under this article, the spouses
Antero and Amanda Agonoy would have been

The Court did not grant the provisional relief

for it would be tantamount to enjoining the
collection of taxes, a peremptory judicial act
which is traditionally frowned upon, unless
there is a clear statutory basis for it.The
Court did not grant the provisional relief for it
would be tantamount to enjoining the collection
of taxes, a peremptory judicial act which is
traditionally frowned upon, unless there is a
clear statutory basis for it. In that regard,
Section 218 of the Tax Reform Act of 1997
prohibits any court from granting an injunction
to restrain the collection of any national
internal revenue tax, fee or charge imposed by
the internal revenue code. A similar philosophy
is expressed by Section 29 of the SMA, which
states that the filing of a petition for review
before the CTA does not stop, suspend, or
otherwise toll the imposition or collection of the
appropriate tariff duties or the adoption of
other appropriate safeguard measures. This
evinces a clear legislative intent that the
imposition of safeguard measures, despite the
availability of judicial review, should not be
enjoined notwithstanding any timely appeal of
the imposition.
First Fil-Sin Leanding Corporation vs.
Padillo
Perusal of the promissory notes and the
disclosure statements pertinent to the July 22,
1997 and September 7, 1997 loan obligations
of respondent clearly and unambiguously
provide for interest rates of 4.5% per annum
and 5% per annum, respectively. Nowhere
was it stated that the interest rates shall be
applied on a monthly basis. Thus, when the
terms of the agreement are clear and explicit
that they do not justify an attempt to read into it
any alleged intention of the parties, the terms
are to be understood literally just as they
appear on the face of the contract. It is only in
instances when the language of a contract is
ambiguous or obscure that courts ought to
apply certain established rules of construction
in order to ascertain the supposed intent of the
parties. However, these rules will not be used
to make a new contract for the parties or to

rewrite the old one, even if the contract is

inequitable or harsh. They are applied by the
court merely to resolve doubts and ambiguities
within the framework of the agreement.
Respondent, on the other hand, avers that the
interest on the loans is per annum as
expressly stated in the promissory notes and
disclosure statements. The provision as to
annual interest rate is clear and requires no
room for interpretation. Respondent asserts
that any ambiguity in the promissory notes and
disclosure statements should not favor
petitioner since the loan documents were
prepared by the latter.
Manila International Airport Authority vs.
Gingoyon
Interpretation of Contracts; In interpreting a
contract, its provisions should not be read in
isolation but in relation to each other and in
their entirety so as to render them effective,
having in mind the intention of the parties and
the purpose to be achieved.In interpreting a
contract, its provisions should be read not in
isolation but in relation to each other and in
their entirety so as to render them effective,
having in mind the intention of the parties and
the purpose to be achieved. The various
stipulations of a contract are to be interpreted
together, attributing to the doubtful ones that
sense which may result from all of them taken
jointly. Thus, in this case, the phrase any
subsequent administrative orders in
paragraph 2.04 should not be read in isolation,
as what petitioner has erroneously done, but
should be read together with the provisions of
paragraph 7.17. Said paragraph provides that
the lease contract may not . . . be modified or
altered except by an instrument in writing duly
signed by the parties hereto and/or by
administrative order duly issued/promulgated
hereafter, that is, after May 29, 1998, the date
the parties signed the lease contract.
Accordingly, for an administrative order to be
incorporated into the contract and thereby
effect an adjustment of the monthly rental, it is
necessary that the administrative order
amending the rates be issued or promulgated
after May 29, 1998. Such is not the case of
A.O. No. 1, Series of 1998, which was issued
much earlier on April 2, 1998.