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: Facts: The appellants, Hart, Miller, and Natividad, were found guilty on a charge of vagrancy under the provisions of Act No. 519. All three appealed and presented evidence showing that each of the defendants was earning a living at a lawful trade or business sufficient enough to support themselves. However, the Attorney-General defended his clients by arguing that in Section 1 of Act No. 519, the phrase “no visible means of support” only applies to the clause “tramping or straying through the country” and not the first clause which states that “every person found loitering about saloons or dram shops or gambling houses,” thus making the 3 appellants guilty of vagrancy. He further argued that it been intended for “without visible means of support” to qualify the first part of the clause, either the comma after gambling houses would have been omitted, or else a comma after country would have been inserted. Issue: WON Hart, Miller and Natividad are guilty of vagrancy under the Attorney-General’s argument based on a mere grammatical criticism. Held: An argument based upon punctuation alone is not conclusive and the effect intended by the Legislature should be the relevant determinant of the interpretation of the law. When the meaning of a legislative enactment is in question, it is the duty of the courts to ascertain, if possible, the true legislative intention, and adopt that construction of the statute which will give it effect. Moreover, ascertaining the consequences flowing from such a construction of the law is also helpful in determining the soundness of the reasoning. Considering that the argument of the Attorney-General would suggest a lack of logical classification on the part of the legislature of the various classes of vagrants and since it was proven that all three of the defendants were earning a living by legitimate means at a level of comfort higher than usual, Hart, Miller and Natividad were acquitted, with the costs de oficio.
JULIO AGCAOILI vs ALBERTO SUGUITAN G.R. No. L-24806, February 13, 1926 JOHNSON, J.: Facts: Julio Agcaoili, Justice of the Peace of the Municipality of Laoag, Ilocos Norte was given an order by the Secretary of Justice Alberto Suguitan to cease to be a justice of peace in obedience to the provisions amended by the Act No. (3107). Judge Agcaoili filed letters of protests and subsequently petitions for a writ of quo warranto after not receiving any response from the Secretary of Justice. Secretary Suguitan answered and set up the defense of prescription. Issue: WON the action of petitioning a writ of quo is barred by the statutes of limitations? Held: As a general principle it may be stated that ordinary statutes of limitation, civil or penal, have no application to quo warranto proceeding brought to enforce a public right. Further, it was an action by the Government that led to this situation, prescription could not be plead as a defense For the state to claim that the statutes of limitation do not apply to it and yet insist that it may plead such statutes to bar the action of quo warranto brought by one of its public officials whom it itself has ousted from office, appears to us to be unjust, unfair, unreasonable, and not within the contemplation of sound jurisprudence. The judgment appealed from should be revoked, and a judgment should be entered ordering the restoration of the appellant to the office from which he was illegally rejected.
CITY OF BAGUlO, REFORESTATION ADMINISTRATION, FRANCISCO G. JOAQUIN, SR., FRANCISCO G. JOAQUIN, JR., and TERESITA J. BUCHHOLZ vs HON. PIO R. MARCOS, Judge of the Court of First Instance of Baguio, BELONG LUTES, and the HONORABLE COURT OF APPEALS G.R. No. L-26100, February 28, 1969 SANCHEZ, J.:
Facts: The jurisdiction of the Court of First Instance of Baguio to reopen the cadastral proceedings under Republic Act 931 was attacked on the grounds of: (1) the reopening petition was filed outside the 40-year period next preceding the approval of Republic Act 931; (2) said petition was not published; and (3) private petitioners, as lessees of the public land in question, have court standing under Republic Act 931. To cite a background information on the third claim, the cadastral proceedings sought to be reopened were instituted on April 12, 1912. Final decision was rendered on November 13, 1922. Lutes filed the petition to reopen on July 25, 1961. Issue: WON the cadastral court have power to reopen the cadastral proceedings upon the application of respondent Lutes? Held: Given that there is a seeming inconsistency between the title and the body of R.A. 931, there is a need to determine legislative intent of the said law. When an obscure expression in the law or where exact or literal rendering of the words would not carry out the legislative intent, the title thereof may be resorted to in the ascertainment of congressional will. Since from the title, there are two phrases to consider the choice of construction, a liberal view should be adopted. With these, the interpretation of the law proves that claims of title under R.A. 931 may be filed there under embrace those parcels of land that have been declared public land and therefore, by that statute, the July 25, 1961 petition of respondent Belong Lutes to reopen the cadastral proceedings come within the 40-year period and is within the power of the cadastral court.
FLORENCIO EUGENIO, doing business under the name E & S Delta Village vs EXECUTIVE SECRETARY FRANKLIN M. DRILON, HOUSING AND LAND USE REGULATORY BOARD (HLURB) AND PROSPERO PALMIANO G.R. No. 109404, January 22, 1996 PANGANIBAN, J.: Facts: Prospero Palmiano on installment basis from Eugenio, the petitioner, and his coowner/developer Fermin Salazar, two lots in the E & S Delta Village in Quezon City. He started to default on amortization payments beginning May 1975 due to the petitioner’s nondevelopment of the said lots. Further, the petitioner sold one of the two lots to Rodolfo and Adelina Relevo upon Palmiano’s cease of payment. Eugenio then filed a petition to set aside the decision of the respondent which affirmed the order of the Housing and Land Use Regulatory Board to “immediately refund to the complainant-appellant Prospero Palmiano all payments made thereon, plus interests computed at legal rates from date of receipt hereof until fully paid." Petitioner avers that the Executive Secretary erred in applying P.D. 957 and in concluding that the non-development of the E & S Delta Village justified private respondent's non-payment of his amortizations. Further, the petitioner avers that inasmuch as the land purchase agreements were entered into in 1972, prior to the effectivity of P.D. 957 in 1976, said law cannot govern the transaction. Issue: WON Executive Secretary Drilon showed a grave abuse in discretion when he applied P.D. 957 and concluded that the non-development of the E & S Delta Village justified private respondent's non-payment of his amortizations. Held: The respondent Executive Secretary did not abuse his discretion, and that P.D. 957 is to be given retroactive effect so as to cover even those contracts executed prior to its enactment in 1976 given that the intent of the law, as culled from its preamble and from the situation, circumstances and conditions it sought to remedy, must be enforced. Moreover, the preamble of the law clearly expresses that the law’s intent is to protect helpless citizens who may fall prey to the manipulations and machinations of "unscrupulous subdivision and condominium sellers," suggesting that to remedy the said alarming situations, P.D. 957 should operate retrospectively even upon contracts already in existence at the time of its enactment.
THE EMPLOYEES' CLUB, INC. vs. CHINA BANKING CORPORATION G.R. No. L-40188 , July 27, 1934 DIAZ, J.: Facts: China Banking Corporation, as mortgage creditor of the Intestate Estate of Jose Javier Go Chioco, appealed the order requiring it to surrender the register of deeds of the City of Manila the duplicate transfer certificate of title No. 21192, in order that the contract of lease evidenced by Exhibit A be noted thereon and entered in the corresponding records. The oppositor-appellant contends that the contract of lease was not registerable in the registry of deeds because: that said contract does not create a real right and that, under the provisions of the Civil Code and the Mortgage Law, only real rights are susceptible of registration in the registry of deeds, with no other exception than those cases in which the lease is for a period exceeding six years, or the rent corresponding to three years is paid in advance, or there is an express covenant requiring the lease. Issue: WON contract of lease was not registerable in the registry of deeds. Held: The court deems it necessary for the appellant to surrender to the register of deeds of the City of Manila the duplicate of transfer certificate of title No. 21192, which it has in its possession, in order that said official may make a notation on the said document as well as on the original thereof and in the corresponding records of his office, of the contract of lease contained in Exhibit A. The appellant forgets, or rather ignores, the fact that the property in question is registered in accordance with the Torrens system: and it forgets furthermore that the latter Act expressly provides that all interests in land registered in the registry under said Act are not only susceptible of registration but must necessarily be registered in order to affect third persons.
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