Arroyo vs.
De Venecia STATUTORY CONSTRUCTION LESSON:
Issue: Is the court empowered to look into allegations that a House
of Congress failed to comply with its soon rules in enacting a law?
Ruling : The supreme court is not empowered to inquire into
allegations that, in enacting a law, a House of Congress failed to
comply with its own rules, in the absence of showing that there was
a violation of a constitutional provision or the rights of private
individuals.
Consequently, mere failure to conform to Rules of Congress does
not have the effect of nullifying the act taken if the requisite number
of members has agreed to a particular measure. But this is subject to
qualification. Where the construction to be given to a rule affects
person other than members of the legislative body, the question
presented is necessarily judicial in character. Even its validity is open
to question in a case where private rights are involved.
The matter complained of concerns a matter of internal procedure
of the House with which the Court should not be concerned. The
question of quorum cannot be raised repeatedly especially when the
quorum is obviously present for the purpose of delaying the
business of the House.
TOLENTINO VS. SEC. OF FINANCE
ISSUE: WON S. No. 1630 did not pass 3 readings on separate days as
required by the Constitution because the second and third readings
were done on the same day.
Held: The President had certified S. No. 1630 as urgent. The
presidential certification dispensed with the requirement not only of
printing but also that of reading the bill on separate days. That upon
the certification of a bill by the President the requirement of 3
readings on separate days and of printing and distribution can be
dispensed with is supported by the weight of legislative practice.
ABAKADA VS. ERMITA
Furthermore, under the “enrolled bill doctrine”, the signing of a
bill by the Speaker of the House and the Senate President and the
certification of the Secretaries if both Houses of Congress that it was
passed are conclusive of its dye enactment.
Doctrine of Enrolled Bill: once a bill passes a legislative body and is
signed into law, the courts assume that all rules of procedure in the
enactment process were properly followed. That is, "[i]f a legislative
document is authenticated in regular form by the appropriate
officials, the court treats that document as properly adopted.
People vs. Purisima
ISSUES OF THE CASE: Are the Informations filed by the People
sufficient in form and substance to constitute the offense of "illegal
possession of deadly weapon" penalized under Presidential Decree
(PD for short) No. 9?
The problem of determining what acts fall within the purview of a
statute, 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.
It is a salutary principle in statutory construction that there exists a
valid presumption that undesirable consequences were never
intended by a legislative measure, and that a construction of which
the statute is fairly susceptible is favored, which will avoid all
objectionable, mischievous, indefensible, wrongful, evil, and
injurious consequence.
Lidasan vs. COMELEC
ISSUE: Is RA 4790, which created Dianaton but which includes
barrios located in another province - Cotabato - to be spared from
attack planted upon the constitutional mandate that "No bill which
may be enacted into law shall embrace more than one subject which
shall be expressed in the title of the bill?
HELD: The baneful effect of the defective title here presented is not
so difficult to perceive. Such title did not inform the members of
Congress as to the full impact of the law; it did not apprise the
people in the towns of Buldon and Parang in Cotabato and in the
province of Cotabato itself that part of their territory is being taken
away from their towns and province and added to the adjacent
Province of Lanao del Sur; it kept the public in the dark as to what
towns and provinces were actually affected by the bill that even a
Congressman from Cotabato voted for it only to find out later on
that it is to the prejudice of his own province. These are the
pressures which heavily weigh against the constitutionality of RA
4790.
Aldayan vs. NPC
HELD: No bill "which may be enacted into law shall embrace more
than one subject which shall be expressed in [its] title . . ." Where
the subject of a bill is limited to a particular matter, the lawmakers
along with the people should be informed of the subject of
proposed legislative measures. This constitutional provision thus
precludes the insertion of riders in legislation, a rider being a
provision not germane to the subject matter of the bill. Alalayan
asserts that the provision objected to is such a rider.
SUMULONG VS. COMELEC
Moreover, a liberal construction of the "one title-one subject" rule
has been invariably adopted by this court so as not to cripple or
impede legislation. Thus, in
The constitutional requirement as now expressed in Article VI,
Section 26(1) “Every bill passed by the Congress shall embrace only
one subject which shall be expressed in the title thereof.” should be
given a practical rather than a technical construction. It should be
sufficient compliance with such requirement if the title expresses
the general subject and all the provisions are germane to that
general subject." The liberal construction of the "one title-one
subject" rule had been further elucidated in Lidasan vs. COMELEC.
Tatad vs. Secretary of DOE
It is also contended that Sec. 5(b) of RA 8180 on tariff differential
violates the provision of the Constitution requiring every law to have
only one subject which should be expressed in its title. The Court did
not concur with this contention. The title need not mirror, fully
index or catalogue all contents and minute details of a law. A law
having a single general subject indicated in the title may contain any
number of provisions, no matter how diverse they may be, so long
as they are not inconsistent with or foreign to the general subject,
and may be considered in furtherance of such subject by providing
for the method and means of carrying out the general subject. The
Court held that Sec. 5 providing for tariff differential is germane to
the subject of RA 8180 which is the deregulation of the downstream
oil industry.
Tanada vs. Tuvera
Tanada vs. Tuvera (1986)
Issue: Whether or not the clause ³unless it is otherwise provided´
refers to the date of effectivity of laws or to the requirement of
publication.
Held: The clause “unless it is otherwise provided´ refers to the date
of effectivity and not to the requirement of publication itself, which
cannot be omitted. Publication is indispensable in every case, but
the legislature in its discretion provide that the usual fifteen day
period shall be shortened or extended. The omission of the said
publication would run against the due process clause and would
deny the public knowledge of the laws. The court held that all
statutes, including those of local application and private laws, shall
be published as a condition for their effectivity. The publication
must be in full since its purpose is to inform the public of the
contents of the law.
PVB EMPLOYEES UNION VS. VEGA
ISSUE: Whether or not RA 7169 became effective on January 2,
1992.

ISSUES:
Whether the presidential decrees in question which contain special
provisions as to the date they are to take effect, publication in the
Official Gazette is not indispensable for their effectivity?
RULING:
Publication in the Official Gazette is necessary in those cases where
the legislation itself does not provide for its effectivity date, for then
the date of publication is material for determining its date of
effectivity, which is the 15th day following its publication, but not
when the law itself provides for the date when it goes into effect.
HELD: The Supreme Court upheld that while as a rule laws take
effect after 15 days following completion of their publication in the
Official Gazette or in a newspaper of general circulation in the
Philippines, the legislature has the authority to provide for
exceptions as indicated in the clause “unless otherwise provided”.
Citing Tanada vs Tuvera, this clause refers to the date of effectivity
and not to the requirement of publication, which cannot in any
event be omitted. The reason is that such omission would affect due
process in so far as it would deny the public knowledge of the laws
that are supposed to govern it.

Article 2 does not preclude the requirement of publication in the

Official Gazette, even if the law itself provides for the date of its
effectivity.

The publication of all presidential issuances of a public nature or of

general applicability is mandated by law. Obviously, presidential
decrees that provide for fines, forfeitures or penalties for their
violation or otherwise impose burdens on the people, such as tax
revenue measures, fall within this category. Other presidential
issuances which apply only to particular persons or class of persons
such as administrative and executive orders need not be published
on the assumption that they have been circularized to all concern.

The Court therefore declares that presidential issuances of general

application, which have not been published, shall have no force and
effect.