Spouses Pascual v.

Spouses Ballesteros

FACTS:

The instant case involves a parcel of land, owned by the following persons, (1) the spouses Albino and
Margarita Corazon Mariano, (2) Angela Melchor (Angela), and (3) the spouses Melecio and Victoria
Melchor (Spouses Melchor). Upon the death of the Spouses Melchor, their share in the subject property
was inherited by their daughter Lorenza Melchor Ballesteros (Lorenza). Subsequently, Lorenza and her
husband Antonio Ballesteros (respondents) acquired the share of Angela. On August 11, 2000,
Margarita, sold their share in the subject property to Spouses Pascual and Francisco. Consequently, the
respondents, claiming that they did not receive any written notice of the said sale in favor of Spouses
Pascual and Francisco, filed with the RTC of Laoag City a Complaint for legal redemption against the
petitioners.

ISSUE: Whether or not that right of redemption by the respondents under Article 1623 of the Civil
Code was seasonably exercised.

RULING:

Yes. Both the letter and the spirit of the New Civil Code argue against any attempt to widen the scope of
the written notice by including therein any other kind of notice such as an oral one, or by registration. If
the intent of the law has been to include verbal notice or any other means of information as sufficient to
give the effect of this notice, there would have been no necessity or reason to specify in the article that
said notice be in writing, for under the old law, a verbal notice or mere information was already deemed
sufficient.

Time and time again, it has been repeatedly declared by this Court that where the law speaks in clear
and categorical language, there is no room for interpretation. There is only room for application. Where
the language of a statute is clear and unambiguous, the law is applied according to its express terms,
and interpretation should be resorted to only where a literal interpretation would be either impossible
or absurd or would lead to an injustice.
Victoria v. COMELEC

FACTS:

Under the LGC, the position of vice-governor should be occupied by the highest ranking Sanggunian
member, and for purposes of succession, ranking in the Sanggunian shall be determined on the basis of
the proportion of votes obtained by each winning candidate to the total number of registered voters in
each district.

In the Elections, petitioner candidate Victoria from the 2nd district garnered 32, 918 votes and
respondent candidate Calisin from the 1st district garnered 28, 335 votes. The COMELEC issued a
resolution certifying respondent as 1st in the order of ranking with petitioner as 2nd ranking member
pursuant to the provisions above.

ISSUE: Whether or not the proportion of the the votes obtained to the number of registered voters of
each district shall be factored to the number of voters who actually voted in determining the ranking
in the Sanggunian.

RULING:

For purposes of succession, ranking in the Sanggunian shall be determined on the basis of the
proportion of votes obtained by each winning candidate to the total number of registered voters in each
district in the immediately preceding local election."

The law is clear that the ranking in the Sanggunian shall be determined on the basis of the proportion of
the votes obtained by each winning candidate to the total number of registered voters in each district.
In such a case, the Court has no recourse but to merely apply the law. The courts may not speculate as
to the probable intent of the legislature apart from the words.
Garcia-Padilla v. Minister Enrile

FACTS:

The case is an application for the issuance of the writ of habeas corpus on behalf of 14 detainees. Sabino
Padilla and 8 others out of the 14 detainees were then having a conference in the dining room at Dr.
Parong’s residence. Prior thereto, all the 14 detainees were under surveillance as they were then
identified as members of the Communist Party of the Philippines. engaging in subversive activities. They
were arrested and later transferred to a facility only the PCs know, hence, the present petition of
Josefina, mother of Sabina, for writ of habeas corpus.

ISSUE: Whether or not the arrests done against Sabino et al were valid.

RULING:

Yes. The suspension of the privilege of the writ of habeas corpus raises a political, not a judicial,
question and that the right to bail cannot be invoked during such a period. PD 1836 and LOI 1211 have
vested, assuming a law is necessary, in the President the power of preventive arrest incident to the
suspension of the privilege of the writ. In addition, however, it should be noted that the PCO has been
replaced by Preventive Detention Action (PDA) pursuant to PD 1877. As provided for in the said decree,
a PDA constitutes an authority to arrest and preventively detain persons committing the
aforementioned crimes, for a period of one year, with the cause or causes of their arrest subjected to
review by the President or the by the Review Committee created for the purpose.
People v. Purisima

FACTS:

Several informations were filed before several courts charging the accused of Illegal Possession of
Deadly Weapon in violation of Presidential Decree #9. The counsel of the defense filed motions to quash
the said informations after which the respondent-courts passed their own orders quashing the said
informations on common ground that the informations did not allege facts constituting ang offense
penalized until PD#9 for failure to state an essential element of the crime, which is, that the carrying
outside of the accused’s residence of a bladed, pointed, or blunt weapon is in furtherance or on the
occasion of, connected with, or related to subversion, insurrection, or rebellion, organized lawlessness
or public disorder.

ISSUE: Whether or not informations filed by the people sufficient in form and substance to constitute
the offense of “Illegal possession of deadly weapon” penalized under Presidential Decree No. 9

RULING:

No. The primary rule in the construction and interpretation of a legislative measure is to search for and
determine the intent and spirit of the law. Legislative intent is the controlling factor. Because of the
problem of determining what acts fall under P.D. 9, it becomes necessary to inquire into the intent and
spirit of the decree and this can be found among others in the preamble or “whereas” clauses which
enumerate the facts or events which justify the promulgation of the decree and the stiff sanctions
stated therein.

The intent of the law is to be ascertained from the words used in its construction. (If legislative intent is
not expressed in some appropriate manner, the courts cannot by interpretation speculate as to an
intent and supply a meaning not found in the phraseology of the law.)
Endencia v. David

FACTS:

Saturnino David was the Internal Revenue Collector who ordered Judges Endencio and Jugo’s salaries. A
case was filed. However, upon construing Article VIII Section 9 of the constitution, it shows that judicial
officers are exempt from paying tax from their salaries and thus considered that the deduction of
salaries from the said judges as a violation from the compensation received by judicial officers.

ISSUE: Whether or not Section 13 of RA 590 is constitutional.

RULING:

No. When it is clear that a statute transgresses the authority vested in the legislature by the
Constitution, it is the duly of the courts to declare the act unconstitutional. Section 13, RA No. 590 is a
clear example of interpretation or ascertainment of the meaning of the phrase found in section 9, Art.
VIII of the Constitution which refers to the salaries of judicial officers. This act interpreting the
Constitution or any part thereof by the Legislature is an invasion of the well-defined and established
province and jurisdiction of the Judiciary. The Legislature may not legally provide therein that a statue
be interpreted in such a way that it may not violate a Constitutional prohibition, thus the
unconstitutionality of Section 13 of RA No. 590.
De Jesus v. Manila

FACTS:

In 1907, Petitioner bought from an original owner a piece of land in Manila which was under the
Torrens system. Apparently, the original owner incorrectly declared the size of the land. So, from
1901 – 1907, the original owner was paying lesser taxes than he should have and same for Petitioner
from 1907 – 1910. Upon finding out that he was not paying the correct amount of taxes, Petitioner paid
the taxes, fees, and interest of P2, 096.49 for the unpaid balance of the years 1901-1910.Soon after, he
protested and filed an action to recover the same amount. Petitioner was awarded P1, 649.82.
Petitioner contends that the supposed taxes from before 1910 were not actually taxes
because they had not yet been assessed. Taxes may not be due and payable until they are assessed.

ISSUE: Whether or not petitioner should still pay the taxes which were not assessed before.

RULING:

No. If a statute needs interpretation or construction, the influence most dominant in that process is the
purpose or intent of the Act. We have held that the general purpose of the Land Registration Act (No.
496) was to create an indefeasible title and one free from all charges, liens and incumbrances except
those preserved against it by special mention in the decree of registration or by provision of law. Section
39 of that Act embodies that purpose in express law. It declares, in effect, that every owner of
registered land shall hold the same free and clear from any and all liens and incumbrances except those
set forth in the decree of registration and those mentioned and excepted in that section.

This being the purpose of the statute, the exceptions named in section 39 will not be enlarged beyond
the actual signification of the words used or extended beyond the limits which the words themselves
actually set.
Republic v. St. Vincent de Paul Colleges Inc.

FACTS:

The instant case arose from two cases filed by the Republic seeking expropriation of certain properties
in the name of St. Vincent de Paul Colleges, Inc. (St. Vincent). Due to St. Vincent's refusal to honor the
order of expropriation, the Republic filed an urgent motion for the issuance of a writ of possession,
which was denied by the lower court. The lower court, however, modified its Order and required the
Republic to immediately pay St. Vincent in an amount equivalent to one hundred percent (100%) of the
value of the property sought to be expropriated. The Republic moved for reconsideration but it was
denied by the lower court. Seeking to avail the extra ordinary remedy of certiorari under Rule 65 of the
Rules of Court, the Republic filed with the CA a motion for additional time of fifteen (15) days within
which to file its petition.

ISSUE: Whether or not CA erred in denying the petition of certiorari for being filed out of time

Yes. In the more recent case of Domdom v. Sandiganbayan, we ruled that the deletion of the clause in
Section 4, Rule 65 by A.M. No. 07-7-12-SC did not, ipso facto, make the filing of a motion for extension
to file a Rule 65 petition absolutely prohibited. We held in Domdom that if absolute proscription were
intended, the deleted portion could have just simply been reworded to specifically prohibit an extension
of time to file such petition. Thus, because of the lack of an express prohibition, we held that motions
for extension may be allowed, subject to this Court's sound discretion, and only under exceptional and
meritorious cases. Indeed, we have relaxed the procedural technicalities introduced under A.M. No. 07-
7-12-SC in order to serve substantial justice and safeguard strong public interest.
Chua v. CSC

FACTS:

Republic Act No. 6683 provided benefits for early retirement and voluntary separation from the
government service as well as for involuntary separation due to reorganization. Deemed qualified to
avail of its benefits are those enumerated in Sec. 2 of the Act. Petitioner Lydia Chua believing that she is
qualified to avail of the benefits of the program, filed an application with respondent National Irrigation
Administration (NIA) which, however, denied the same. A recourse by petitioner to the Civil Service
Commission yielded negative results, citing that her position is co-terminous with the NIA project which
is contractual in nature and thus excluded by the enumerations under Sec.3.1 of Joint DBM-CSC Circular
Letter No. 89-1, i.e. casual, emergency, temporary or regular employment.

ISSUE: Whether or not the petitioner is entitled to the benefits granted under Republic Act No. 6683.

RULING:

Yes. Petitioner was established to be a co-terminous employee, a non-career civil servant, like casual
and emergency employees. The Supreme Court sees no solid reason why the latter are extended
benefits under the Early Retirement Law but the former are not. It will be noted that Rep. Act No. 6683
expressly extends its benefits for early retirement to regular, temporary, casual and emergency
employees. But specifically excluded from the benefits are uniformed personnel of the AFP including
those of the PC-INP. It can be argued that, expressio unius est exclusio alterius but the applicable maxim
in this case is the doctrine of necessary implication which holds that “what is implied in a statute is as
much a part thereof as that which is expressed”. The Court believes, and so holds, that the denial by the
respondents of petitioner’s application for early retirement benefits under R.A. No. 6683 is
unreasonable as petitioner had filed an application for voluntary retirement within a reasonable period
and she is entitled to the benefits of said law.
Ebarle v. Sucaldito

FACTS:

Ebarle, was then provincial governor of Zamboanga & a candidate for re-election in 1971 local elections.
The Anti-Graft League of the Philippines filed complaints with the city fiscal against the petitioner for
violations of RA 3019 (Anti-Graft Law) and Articles 171, 182,183, 213, and 318 of the Revised Penal
Code. The petitioner filed petitions for prohibition and certiorari in CFI but they were dismissed. He
petitioned to the Supreme Court and alleged that the City Fiscal and Anti-Graft League failed to comply
with the provisions of EO 264, which outlined the procedure how complainants charging the
government officials and employees with the commission of irregularities should be guided.

ISSUE: Whether or not EO 264 is applicable in the case at bar.

RULING:

No. It is plain from the very wording of the Order that it has exclusive application to administrative, not
criminal complaints. The very title speaks of "COMMISSION OF IRREGULARITIES." There is no mention,
not even by implication, of criminal "offenses," that is to say, "crimes." While "crimes" amount to
"irregularities," the Executive Order could have very well referred to the more specific term had it
intended to make itself applicable thereto. Clearly, the Executive Order simply consolidates these
existing rules and streamlines the administrative apparatus in the matter of complaints against public
officials. It is moreover significant that the Executive Order in question makes specific reference to
"erring officials or employees ... removed or otherwise vindicated. If it were intended to apply to
criminal prosecutions, it would have employed such technical terms as "accused", "convicted," or
"acquitted." While this is not necessarily a controlling parameter for all cases, it is here material in
construing the intent of the measure.