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Legazpi v Minister of Finance - SolGen (contesting HC issuance): Arrest was valid

because detainees were arrested for offenses under


- Petitioner (a member of interim BP) is questioning PD Proc. No. 2045 and mandated by the President through
1840 the PCO
- Petitioner: PD is invalid because it was issued not in
concurrence with the Interim BP ISSUE: W/N the arrest was valid

Issue: W/N the president can act as the legislative authority Held: Yes
by himself - The detainees were caught in flagrante delicto planning
a subversive act, and arrest was done to prevent a
Held: Yes potential rebellion planned by the detainees
- PD 1840 was issued under Amendment No. 6 (issued - PCO merely validates the detention of offenses
in 1976) covered by Proc. No. 2045 (w/c provides for the
- Amendment no. 6: interpreted by the Court as a offenses covered AND suspends the writ of HC)
constitutional authority vested to the President so he since writ is suspended by Proc. No. 2045,
can act swiftly in times of emergency or in cases he detention is legal
deems needs immediate action (also, as an - LOI: a mere directive to the AFP on how the military
alternative to Martial Law) can arrest violators of Proc. No. 2045
- Amendment no. 6 allows Marcos to act as a legislator Both PCO and LOI are not controlling but only
without the concurrence of the Interim BP supplement Proc. No. 2045
But, if president wants to include LOI as law, he can
Garcia-Padilla v Ponce Enrile do so in exercise of his legislative power
When can President wield legislative powers?
- Petitioner Josefina Garcia-Padilla is questioning the Amendment No. 6 (See Legazpi case)
arrest and subsequent detention of 14 individuals
(which includes her son), and filed a petition for writ of Aquino v COMELEC
habeas corpus and mandamus
- Detainees were arrested by virtue of a Presidential Petitioners are contesting the validity of the
Communication Order (PCO) in relation to Presidential Decrees issued by President Marcos
Proclamation No. 2045 (the PDs call for a referendum and the
- The writ of habeas corpus was then issued by the appropriation of funds for said referendum)
Court
ISSUE: W/N the presidential decrees issued are valid - Postmaster General denied petitioner, relying on the
opinion of the DOJ on what constitutes a gift
Held: Yes enterprise, violated provisions of the Postal Law
- First: SC established that Marcos is the de jure - Caltex filed for declaratory relief before TC and was
president of the Philippines granted
1973 Constitution was ratified while he was the - Respondent appealed TC decision before SC
incumbent president (consti commission/public had
Marcos in mind when they ratified the Constitution) ISSUE: W/N the Caltex promotion violated the Postal Law
1973 constitution provides that President
decrees/issuances shall be part of the law of the Held: No
land - Postal Law condemns any lottery, gift enterprise, or
- Second: Marcos issued the assailed PDs during martial scheme for the distribution of money or any property by
law lot, chance or drawing of any kind.
Martial Law allowed Marcos to wield legislative - Three essential elements of lottery: prize (), chance
authority () and consideration (none because Caltex does not
PDs are essential to the security and preservation require customers to pay a fee or purchase their
of the public. products to participate); therefore, it is not considered a
1973 Constitution itself provides Presidential lottery
decrees and issuances before ratification of said - In the Postal Law, gift enterprise was used in
consti shall form part of the law of the land. association with the term lottery
noscitur a sociis term under a statute should be
Caltex v. Palomar accorded no other meaning other than that of the word
it is associated with; hence, gift enterprise = lottery
- Caltex implemented a contest called the Hooded
Pump Contest, which would award prizes to Bolos v Bolos
contestants by simply guessing the number dispensed
by the hooded pump. - Petitioner Cynthia filed for declaration of nullity (under
- There is no need to pay a fee or purchase a Caltex Art 36) of her marriage with respondent Danilo
product to participate in said contest - RTC granted the petition and declared their marriage
- Caltex asked the permission of the Postmaster General null and void
(respondent) in anticipation of its usage of mail for the
promotion and communication of the contest
- Danilo filed an appeal before the CA without filing a - Court conceded that abstractly speaking, construction
motion for consideration first (as required by AM 02-11- and interpretation have different meanings
10-SC), which CA granted. - BUT: in common usage or practice, both words have
- CA: AM 02-11-10-SC does not apply to the spouses the same meaning and significance
because it was contracted before FC - Therefore: Under Act of 1907, construction and
- Petitioner (on appeal to SC): AM should apply interpretation have the same meaning, and the Court
has jurisdiction of the case
ISSUE: W/N AM 02-11-10-SC should apply

Held: No Roberts v Portland Water District


- Sec. 1 of AM: It only applies to marriages under the
Family Code; spouses were married in 1980 - Petitioners are land owners whose land was taken
- When the law is clear and free of doubt/ambiguity, (thru eminent domain) by the respondent
there is no room for construction or interpretation - Petitioners contend that the taking of their land was
(verba legis) unnecessary
- Commissioners determined the taking of the land was
necessary due to the exigency of the situation and
determined a compensation that would benefit
US v Keitel respondent
- Petitioners wanted to be exempted from the ruling
- District Court of Colorado granted the motion to quash
(on two counts) filed by respondent ISSUE: W/N the taking of the land was appropriate
- US appealed to SC, but respondent is contending that
the Court does not have jurisdiction on the case (citing Held: Yes
the Act of March 1907) because the Court only - Court deemed that the word particular (by looking at
construes and does not interpret the law all and not just one provision of the statute) should
mean detailed within the context of the law
ISSUE: W/N statute construction is different from statute - Respondent must specify the details of the land being
interpretation appropriated
- BUT, due to the exigency of the situation, the taking of
Held: No the land from petitioners is valid (provided they are
justly compensated)
- Construction draws warranted conclusions not always - 1988: He was convicted under the terms of the then
included in the direct expression of the law guidelines (LSD + blotter paper)
- 1991: Chapman ruling: paper + LSD need to be
FDC v ERC weighed to determined LSD possession
- 1993: Congress Sentencing Commission passed a
- Petition for injunction and TRO issuance was filed by new guideline (which has retroactive effect) in
FDC against ERC contending the ERC Order (w/c calculating LSD (each dose has a presumed weight)
would allow MERALCO to increase electric utility rates) - Weight needed to be sentenced to 10 years in prison =
- FDCs argument (among others): Order is void 10grams.
because ERC has no legal or statute authority to do so - Neals LSD under old guideline: 109 g; under new
- Petitioners: EPIRA repealed CA 142 and EO 172 guideline: 4g
(creation of ERB) both of which grant ERB (ERCs
precursoRs) the power to issue provisional orders;
power to issue provisional orders would be ISSUE: W/N the new guideline shall be controlling over
contradictory to EPIRA provision in protecting public the Chapman ruling
interest
Held: No,
ISSUE: W/N ERC has the authority to issue assailed order - Court looked at the intent of the Congress Sentencing
Commission and concluded that:
Held: Yes it is doubtful that new guidelines intended to
- EPIRA: provides a structure for the privatization of the replace Chapman guidelines and that the legislative
energy industry so the services can be improved intended that the new guidelines calculation to be
- EPIRA did not repeal said laws, but supplemented it (it INDEPENDENT of the guidelines used in Chapman;
added new powers to ERC apart from those already and that the old guideline shall be controlling in case
wielded by ERB) of conflict between the two
- Implied repeals are not favored: In fact, EPIRA
specifies the laws it repealed Illinois Brick v Illinois
- Legislative body is presumed to know the existing laws
- Petitioners are manufacturers and distributors of
Neal v US concrete bricks in Chicago while respondents is the
State of Illinois acting on behalf of all its local
- Petitioner Neal was arrested for possession of LSD government units
- Respondent filed an antitrust lawsuit vs petitioner for - Respondents used an opinion penned by Abad-Santos
violating section 4 of the Clayton Act ( himself (during his time as Justice Secretary) in order
- State of Illinois: petitioner engaged in a conspiracy to to bolster their argument
fix the prices of concrete blocks and due to this, they
(respondents) paid more than the market value of said ISSUE: W/N the opinion of Abad-Santos (as DOJ Secretary)
materials is mandatory
- Petitioner: Invoking decision in Hanover Shoe v US,
only DIRECT buyers are allowed to file an action vs Held: No
them - Jurisprudence will still be followed over the opinion of a
member of the Executive Branch (ironically, Abad-
ISSUE: W/N Hanover Shoe decision can apply in this case Santos himself)
- As a government employee, Abad-Santos contributed
Held: Yes 5% of his salary for his pension, and thus his family is
- In the absence of any proof that the court erred in the entitled to recoup said contributions
Hanover Shoe ruling, the Court needs to adhere to - For the purposes of justice and equity, a martyr like
past jurisprudence (stare decisis) Abad-Santos cannot be deprived of his benefits in
which he duly contributed as a govt. employee

Abad v Auditor General


PNOC v CA
- For his service and patriotism as the Chief Justice
during the Japanese invasion (w/c led to his death), -
Jose Abad-Santos widow was rewarded a lump sum
(Commonwealth Act 708)
- However, during his time as Associate Justice of the Union Pac v US
SC, Abad-Santos secured a life insurance policy under
Commonwealth Act 186 - Union Pac bougt an action vs US to recover
- Respondent: As petitioner is already compensated for compensation due for services rendered
under CA 708, she can no longer collect the pension - 1950: Union Pac and US government entered into a
under CA 186 contract to use the petitioners railway to deliver US
mail
- Part of the contract states the fixed compensation of - Business as defined in Sec. 193 should be read in
the govt to petitioner relation to Sec. 178 of the Tax Code
- 1962: a new statute was enacted in which the - Words/phrases should be construed in the whole
compensation of petitioner was placed in the hands of context of the tax code, not individually or per section
the Postmaster General (ut magis valeat quam pereat)

ISSUE: W/N Act of 1862 applies Salaysay v. Castro

Held: No - Salaysay became the acting Mayor of San Juan del


- Act of 1862 did not change the provisions of the Monte, Rizal when the incumbent mayor was
contract between petitioner and US Govt, which is suspended
considered a private contract. - While acting Mayor, he filed for CoC as Mayor for
upcoming elections
Collector of Internal Revenue v. Manila Lodge - His opponents claim that the filing is a violation of Sec.
27 of the Revised Election Code, and he should be
- CIR assessed taxes of Manila Lodge and concluded deemed automatically resigned
that they should be liable to taxes from 1946-1953 and - Salaysay: Sec. 27 does not apply to him
1954-1955
- CIR cited Sec. 178 (privilege taxes on business) and Issue: W/N Salaysay is covered by Sec. 27 of the Revised
Sec. 193 (fixed taxes on liquor retailers) of the Tax Election Code
Code
- CTA: ruled in favor of Manila Lodge Held: Yes
defined business as engaged in profit and - SC looked into the history of Sec. 27 (from
livelihood Commonwealth Act 666 up to the present)
Manila Lodge only sells liquor to cover for - SC concluded that the intent of the legislative body is
operational expenses to extend the benefit and privilege to incumbent
officials (both elected and appointed)
Issue: W/N CTA ruling is correct - Salaysay, being temporary Mayor, is covered by Sec.
27 of REC
Held: Yes - Ascertain the intention of the lawmakers (ratio legis est
- Petitioner cannot rely on a definition of a word from a anima)
single section of the Tax Code

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