LEGISLATIVE HISTORY

CASCO V GIMENEZ STRICT AND LIBERAL CONSTRUCTION

1. Dispute was between Casco and the Auditor General PEA V HOR
2. The resolution requires the interpretation of exemption under RA
2609 which use urea formaldehyde
3. Offered in support of Cascos interpretation: the bill approved in INTERPRETATION OF WORDS AND PHRASES
Congress as containing and between the two terms as well as I. GENERAL AND PARTICULAR
statements made during the deliberations of the bill.
4. ENROLLED BILL DOCTRINE SC ruled that MATAGUINA INTEGRATED WOOD V CA
a. Individual statements dont necessarily reflect the view of the TAN V PEOPLE
Senate much less the HoR
b. Enrolled bill which uses the term urea formaldehyde instead
of urea and formaldehyde is conclusive upon the courts as
regards the tenor of the measure passed by Congress
II. NOSCITUR A SOCIIS

FARIAS V COMELEC DAI-CHI V VILLARAMA

1.
PEOPLE V BELLO

BANAT V COMELEC
III. EJUSDEM GENERIS

MAGTAJAS V PRYCE PROPERTIES CORP.

PBA V CA

NAVARRO V EXECUTIVE SECRETARY

LIWAG V HAPPY GLENN

IV. EXPRESSION UNIUS

 SAN PABLO MANUFACTURING V BIR
VI. CASIS OMISSUS
1. The dispute involves claim of exemption from millers tax. SPMC
is a company engaged in the business of milling, manufacturing SPS. DELFIN V ST JAMES HOSPITAL
and exporting of coconut oil and other allied products. It was
assessed and ordered to pay by the CIR a deficiency millers tax
and manufacturers sales tax.

2. Interpretation of Sec 168 of the Tax Code providing for VII. UBI LEX NON DISTINGUIT NEC NOS DISTINGUERE DEBEMOS
exemptions from millers tax. According the SPMC, the provisos
contemplate two exemptions: RAMIREZ V CA
a. Milled products in their original state were actually
exported by the miller himself or by another person
b. The milled products sold were actually exported as an
ingredient or part of any manufactured article by the TY-DELGADO V HRET
buyer or manufacturer. The exportation may be effected
by the miller himself or by the buyer/manufacturer.
Since UNICHEM, the buyer, subsequently exported said
products, SPMC should be exempted from the millers
tax. VIII. REDDENDO SINGULAR SINGULIS
3. SC concluded that the language of the exemption proviso did not
warrant the interpretation advanced by SPMC. It did not provide PEOPLE V TAMANI
that the exportation made by the purchaser of the materials
enumerated in the exempting clause or the manufacturer of
products using such materials covered by the exemption.

SPMC;s interpretation unduly enlarged the scopre of the AMADORA V CA

exemption.

ATERLING SELECTIONS V LAGUNA LAKE DEVELOPMENT

V. DISSIMILUM DISSMILIS EST RATIO IX. MANDATORY AND DIRECTORY LANGUAGE

GARVIDA V SALES PHILIPPINE REGISTERED ELECTRICAL PRACTITIONERS V FRANCIA

X. DOCTRINE OF NECESSARY IMPLICATION

PEPSI-COLA PRODUCTS V SECRETARY OF LABOR

XI. CONSTRUCTION OF STTUTE AS A WHOLE

PITC V COMISSION ON AUDIT

XII. CONSTRUCTION IN RELATION TO OTHER STATUTES

XIII.

CALINGING V CA

KORUGA V ARCENAS