​I.

​ ​STATUTORY CONSTRUCTION RULES

CASE: Floresca vs. Philex Mining 136 SCRA 506

T: The topic, limitation on the power of courts to construe

MJ: Judicial Legislation is the power of the courts to ​FILL IN THE GAPS OF THE LAW LEFT,
INTENTIONALLY OR UNINTENTIONALLY, BY THE LEGISLATIVE​.

MN: What it did was a mere implementation of the Constitution and relevant statutes. Secs. 6, 7, and
9 of Art. II of 1973 Constitution guarantees social justice, establishes adequate services in
employment, and protects labor. With these provisions, the present court only gave effect to the
rights petitioners are entitled to. No legislation occurred, because the principles are already present
and need only be applied.

CASE: Petitioner-Organizations v. Executive Secretary, G.R. Nos. 147036-37, April 10, 2012

T:

MJ: Where there are serious allegations that a law has infringed the Constitution, it becomes not only
the right but the duty of the Court to look into such allegations and, when warranted, uphold the
supremacy of the Constitution. Under the doctrine of constitutional supremacy, if a law or contract
violates any norm of the constitution that law or contract whether promulgated by the legislative or
the executive branch or entered into by private persons for private purposes is null and void and
without any force and effect. Thus, since the Constitution is the fundamental, paramount and supreme
law of the nation, it is deemed written in every statute and contract.

MN: Section 2 of P.D. 755, Article III, Section 5 of P.D. 961, and Article III, Section 5 of P.D. 1468
completely ignore the fact that coco-levy funds are public funds raised through taxation. And since
taxes could be exacted only for a public purpose, they cannot be declared private properties of
individuals although such individuals fall within a distinct group of persons.

But the assailed provisions, which removed the coco-levy funds from the general funds of the
government and declared them private properties of coconut farmers, do not appear to have a color of
social justice for their purpose. The declarations do not distinguish between wealthy coconut farmers
and the impoverished ones. Consequently, such declarations are void since they appropriate public
funds for private purpose and, therefore, violate the citizens’ right to substantive due process.

CASE: Lidasan v. COMELEC

T: Yes, R.A. 4790 is unconstitutional and the resolutions of COMELEC and to prohibit from
implementing the same for electoral purposes​ should be nullified.

MJ: The general rule is that where part of a statute is void, as repugnant to the Organic Law, while
another part is valid, the valid portion if separable from the invalid, may stand and be enforced. But in
order to do this, the valid portion must be so far independent of the invalid portion that it is fair to
presume that the Legislature would have enacted it by itself if they had supposed that they could not
constitutionally enact the other. . . Enough must remain to make a complete, intelligible, and valid
statute, which carries out the legislative intent. . . . The language used in the invalid part of the
statute can have no legal force or efficacy for any purpose whatever, and what remains must express
the legislative will independently of the void part, since the court has no power to legislate.

MN: In the case at bar, The phrase “in the Province of Lanao del Sur,” is misleading because it did not
inform the concerned parties, particularly the affected people of the 2 towns of Cotabato, of the full
impact of the law. Moreover, a change of boundaries of two (2) provinces could not be considered as a
mere effect of the enacted law since it is as important as creating a new municipality, which the title
did not reflect. Thus, the resolutions of COMELEC and to prohibit from implementing the same for
electoral purposes​ should be nullified.

CASE: Tatad v. Executive Secretary, G.R. No. 124360, November 5, 1997

T: The court found that the following provisions violate Section 19 of Article XII of the constitution:
Section 5(b), Section 6 and Section 9(b) , therefore making R.A. 8180 IS UNCONSTITUTIONAL and
E.O. 372 VOID

MJ: The general rule is that where part of a statute is void, as repugnant to the Organic Law, while
another part is valid, the valid portion if separable from the invalid, may stand and be enforced. But in
order to do this, the valid portion must be so far independent of the invalid portion that it is fair to
presume that the Legislature would have enacted it by itself if they had supposed that they could not
constitutionally enact the other. . . Enough must remain to make a complete, intelligible, and valid
statute, which carries out the legislative intent. . . . The language used in the invalid part of the
statute can have no legal force or efficacy for any purpose whatever, and what remains must express
the legislative will independently of the void part, since the court has no power to legislate.

MN: In this case, R.A. No. 8180 violated Sec. 19, Article XII of the Constitution prohibiting
monopolies, combinations in restraint of trade and unfair competition.

The provision on inventory widens the balance of advantage of Petron, Shell and Caltex against
prospective new players. Petron, Shell and Caltex can easily comply with the inventory requirement of
R.A. No. 8180 in view of their existing storage facilities. Prospective competitors again will find
compliance with this requirement difficult as it will entail a prohibitive cost. The construction cost of
storage facilities and the cost of inventory can thus scare prospective players. Their net effect is to
further occlude the entry points of new players, dampen competition and enhance the control of the
market by the three (3) existing oil companies. As afore discussed, the 4% tariff differential and the
inventory requirement are significant barriers which discourage new players to enter the market.

CASE: Central Bank Employees Association, Inc. v. BSP, 446 SCRA 299

T: The last paragraph of Section 15 (c), Article II of RA No 7653, is unconstitutional.

MJ: Applying the doctrine of Relative Constitutionality, the fact that a statute is constitutional at first
does not mean it is constitutional forever. The subsequent changes in the original circumstance
surrounding the law would affect its validity.

MN: In the case at bar, it is clear in the legislative deliberations that the exemption of officers (SG 20
and above) from the SSL was intended to address the BSP’s lack of competitiveness in terms of
attracting competent officers and executives. It was not intended to discriminate against the
rank-and-file and the resulting discrimination or distinction has a rational basis and is not palpably,
purely, and entirely arbitrary in the legislative sense. However, in the subsequent passages of the
amendment on the charters of other GFI, the surrounding circumstances of the case changed.
The subsequent amendments of the other GFIs’ charter (i.e., express authorization to determine and
institute its own compensation and wage structure, and explicit exemption – without distinction as to
salary grade or position – all employees of the GFI from the SSL) resulted to the oppressive results of
Congress’ inconsistent and unequal policy towards the BSP rank-and-file and those of the seven other
GFI. In the case at bar, it is precisely the fact that as regards the exemption from the SSL, there are
no characteristics peculiar only to the seven GFIs or their rank-and-file so as to justify the exemption
which BSP rank-and-file employees were denied (not to mention the anomaly of the SEC getting one).
The distinction made by the law is not only superficial, but also arbitrary. It is not based on substantial
distinctions that make real differences between the BSP rank-and-file and the seven other GFIs.

The subsequent grant to the rank-and-file of the seven other GFIs and continued denial to the BSP
rank-and-file employees of the exemption from SSL breached the latter’s right to equal protection.
The equal protection clause does not demand absolute equality but it requires that all persons shall be
treated alike, under like circumstances and conditions both as to privileges conferred and liabilities
enforced

CASES: Limkaichong v. COMELEC, G.R. No. 178831-32, July 30, 2009 || See also Araneta v.
Dinglasan, supra [Re: effect of the death of a justice J. Perfecto]

T: The proclamation of Limkaichong is valid.

MJ: SC Rules state that a DRAFT DECISION being circulated, but not yet promulgated is NOT
BINDING. Until such time that there will be a promulgation of decision, the court can still change their
mind. Concurrence on a decision means only that they agree with the decision result, but the justices
are entitled to their own reasoning behind such decisions.

MN: In this case, the COMELEC Second Division rendered its Joint Resolution dated May 17, 2007. On
May 20, 2007, Limkaichong timely filed with the COMELEC En Banc her motion for reconsideration as
well as for the lifting of the incorporated directive suspending her proclamation. The filing of the
motion for reconsideration effectively suspended the execution of the May 17, 2007 Joint Resolution.
Since the execution of the May 17, 2007 Joint Resolution was suspended, there was no impediment to
the valid proclamation of Limkaichong as the winner. Section 2, Rule 19 of the COMELEC Rules of
Procedure provides: “Period for Filing Motions for Reconsideration. – A motion to reconsider a decision,
resolution, order or ruling of a Division shall be filed within five (5) days from the promulgation
thereof. ​Such motion, if not pro forma, suspends the execution for implementation of the decision,
resolution, order and ruling.”

ARANETA Case:

1.) J. Perfecto died 9 days before the promulgation of decision. 2.) J. Perfecto’s vote can no longer be
counted according to the Rules of Court because he is no longer part of the SC. 3.) He may be in
favour of the Majority Decision, but since he has not signed it yet, therefore his vote must not be
recognized. 4.) Any substitute Justice shall be entitled to their own decision and opinion on a case,
and shall not be required to follow the original decision of the deceased Justice.

CASES: Senarillos v. Hermosisima, G.R. No. L-10662, December 14, 1956

T: Sibonga had no jurisdiction to investigate the Chief of Police Senarillos

MJ: Judicial decisions applying or interpreting the laws or the Constitution shall form part of the legal
system of the Philippines as of the date that law was originally passed.

MN: That the decision of the Municipal Council of Sibonga was issued before the decision in Festejo vs.
Mayor of Nabua was rendered, would be, at the most, proof of good faith on the part of the police
committee, but can not sustain the validity of their actions. It is elementary that the interpretation
placed by this Court upon Republic Act 557 constitutes part of the law as of the date it was originally
passed, since this Court's construction merely establishes the contemporaneous legislative intent that
the interpreted law carried into effect.

Phil. International Trading Corp. v. COA, G.R. No. 205837, November 21, 2017

Respondent Commission gravely abused its discretion amounting to lack or excess of

jurisdiction in issuing the assailed rulings which is contrary to settled jurisprudence.

T:

MJ: Judicial decisions applying or interpreting the laws or the Constitution shall form part of the legal
system of the Philippines as of the date that law was originally passed. Time and again, it has been
held that every statute must be so interpreted and brought in accord with other laws as to form a
uniform system of jurisprudence.

MJ: In the absence of a manifest and specific intent from which the same may be gleaned, Section 6
of Executive Order No. 756 cannot be construed as an additional alternative to existing general
retirement laws and/or an exception to the prohibition against separate or supplementary insurance
retirement or pension plans as aforesaid. Aside from the fact that meaning that does not appear nor is
intended or reflected in the very language of the statute cannot be placed therein by construction,
petitioner would likewise do well to remember that repeal of laws should be made clear and express.
Repeals by implication are not favored as laws are presumed to be passed with deliberation and full
knowledge of all laws existing on the subject, the congruent application of which the courts must
generally presume. For this reason, it has been held that the failure to add a specific repealing clause
particularly mentioning the statute to be repealed indicates that the intent was not to repeal an
existing law on the matter, unless an irreconcilable inconsistency and repugnancy exists in the terms
of the new and old laws.

CASES: People v. Santayana, G.R. No. L-22291, November 15, 1976 (in relation to People v.
Mapa, G.R. No. L-22301, August 30, 1967 and People v. Macarandang, G.R. No. L-12088,
December 23, 1959)

T:

MJ: Generally, laws shall have no retroactive effect, unless the contrary is provided. Applying the
Operative Fact Doctrine, acts done pursuant to a law which was subsequently declared
unconstitutional remain valid, but not when the acts are done after the declaration of
unconstitutionality.

MN: In the present case, Santayana was appointed as CIS secret agent with the authority to carry and
possess firearms. He was issued a firearm in the performance of his official duties and for his personal
protection. Application of license was unnecessary, according to Col. Maristela, as the firearm is
government property. No permit was issued, according to Capt. Adolfo Bringas as he was already
appointed as a CIS agent. Even if the case of People vs. Mapa revoked the doctrine in the
Macarandang case, this was made only on 30 August 1967, years after the accused was charged.

Columbia Pictures, Inc. v. CA, G.R. No. 110318, August 28, 1996

T: No. The 20​th Century Fox ruling cannot be retroactively applied to the instant case to justify the
quashal of the search warrant.

MJ: Judicial interpretation becomes a part of the law as of the date that law was originally passed,
subject only to the qualification that when a doctrine of this Court is overruled and a different view is
adopted, and more so there is a reversal thereof, the new doctrine should be applied prospectively
and should not apply to parties who relied on the old doctrine and acted in good faith.

MN: In the case at bar, the 20th Century Fox case was nonexistent in December 198u when Search
Warrant 87-053 was issued by a lower court. It is indisputable, therefore, that at the time of the
application, or on December 14,1987, the lower court did not commit any error nor did it fail to
comply with any legal requirement for the valid issuance of search warrant.

CASE: Sameer Overseas Placement v. Cabiles, G.R. No. 170139, August 5, 2014

T: Yes, Cabiles was entitled to the unexpired portion of her salary due to illegal dismissal.

MJ: ​Applying the Operative Fact Doctrine, acts done pursuant to a law which was subsequently
declared unconstitutional remain valid, but not when the acts are done after the declaration of
unconstitutionality.
MN: In Serrano v. Gallant Maritime Services, Inc. and Marlow Navigation Co., Inc., this court ruled
that the clause “or for three (3) months for every year of the unexpired term, whichever is less” is
unconstitutional for violating the equal protection clause and substantive due process. A statute or
provision which was declared unconstitutional is not a law. It “confers no rights; it imposes no duties;
it affords no protection; it creates no office; it is inoperative as if it has not been passed at all.” The
Court said that they are aware that the clause “or for three (3) months for every year of the unexpired
term, whichever is less” was reinstated in Republic Act No. 8042 upon promulgation of Republic Act
No. 10022 in 2010.

​I.​ ​STATUTORY CONSTRUCTION RULES

Republic v. Manalo, G.R. No. 221029, April 24, 2018

T: Yes, a Filipino citizen has the capacity to remarry under Philippine law after initiating a divorce
proceeding abroad and obtaining a favorable judgment against his/her alien spouse who is capacitated
to remarry.

MJ: Applying the principle of constitutional construction, Verba legis, that is, wherever possible, the
words used in the Constitution should be given their ordinary meaning except where technical terms
are employed and Ratio legis est anima, meaning that the words of the Constitution should be
interpreted in accordance with the intent of its frame.

MN: Based on a clear and plain reading of the provision, it only requires that there be a divorce validly
obtained abroad. The letter of the law does not demand that the alien spouse should be the one who
initiated the proceeding wherein the divorce decree was granted. It does not distinguish whether the
Filipino spouse is the petitioner or the respondent in the foreign divorce proceeding. The legislature is
presumed to know the meaning of the words, to have used words advisedly, and to have expressed its
intent by the use of such words as are found in the statue. Verbal egist non est recedendum, or from
the words of a statute there should be no departure.

Assuming arguendo that the word “obtained” should be interpreted to mean that the divorce
proceeding must be actually initiated by the alien spouse, still, the Court will not follow the letter of
the statute when to do so would depart from the true intent of the legislature or would otherwise yield
conclusions inconsistent with the general purpose of the act. Laws have ends to achieve, and statutes
should be so construed as not to defeat but to carry out such ends and purposes.

Bustamante v. NLRC, 265 SCRA 61

Relevant provision: Art. 279 provided that an unjustly dismissed employee shall be entitled
“​to his back wages computed from the time his compensation was withheld from him up to
the time of his reinstatement.”

T: Yes, they are entitled to their full backwages.

MJ: Applying the principle of constitutional construction, Verba legis, that is, wherever possible, the
words used in the Constitution should be given their ordinary meaning except where technical terms
are employed.

MN: Conformably with the evident legislative intent of RA 6715, backwages to be awarded to an
illegally dismissed employee, should not, as a general rule, be diminished or reduced by the earnings
derived by him elsewhere during the period of his illegal dismissal. The underlying reason for this
ruling is that the employee, while litigating the legality (illegality) of his dismissal, must still earn a
living to support himself and family, while full backwages have to be paid by the employer as part of
the price or penalty he has to pay for illegally dismissing his employee.

Thus, a closer adherence to the legislative policy behind RA 6715 points to “full backwages” as
meaning exactly that, i.e., without deducting from backwages the earnings derived elsewhere by the
concerned employee during the period of his illegal dismissal. In other words, the provision calling for
“full backwages” to illegally dismissed employees is clear, plain and free from ambiguity and,
therefore, must be applied without attempted or strained interpretation. Index animi sermo est
(literally “speech is the index of intention”).

IBAA Employees Union v. Inciong, 132 SCRA 663

T: No, employees are excluded from the benefit of holiday pay.

MJ: It is elementary in the rules of statutory construction that when the language of the law is clear
and unequivocal the law must be taken to mean exactly what it says.

MN: In the case at bar, the provisions of the Labor Code on the entitlement to the benefits of holiday
pay are clear and explicit- it provides for both the coverage of and exclusion from the benefits. In
Policy Instruction 9, the then Secretary of Labor categorically state that the benefit is principally
intended for daily paid employees, when the law clearly states that every worker shall be paid their
regular holiday pay. While it is true that the contemporaneous construction placed upon a statue by
executive officers whose duty is to enforce it should be given great weight by the courts, still if such
construction is so erroneous, the same must be declared as null and void​.

IRR runs ultra vires as it goes beyond the text of the law.

CASES: Pascual v. Pascual-Bautista, 207 SCRA 561

WON Article 992 of the CC can be interpreted to exclude recognized natural children from
the inheritance of the deceased.

T: No. The petition is devoid of merit. Petition dismissed.

MJ: Verily, the interpretation of the law desired by the petitioner may be more humane but it is also
an elementary rule in statutory construction that when the words and phrases of the statute are clear
and unequivocal, their meaning must be determined from the language employed and the statute
must be taken to mean exactly what is says Dura lex sed lex.

MN: Eligio Pascual is a legitimate child but petitioners are his illegitimate children and the term
“illegitimate” refers to both natural and spurious. The issue in the case at bar, had already been laid to
rest in Diaz v. IAC, where this Court ruled that under Art.992 of the Civil Code, there exists a barrier
or iron curtain in that it prohibits absolutely a succession ab intestado between an illegitimate child
and the legitimate children and relatives of the father or mother of said legitimate child.

CASE: People v. Santayana, 74 SCRA 25 in relation to People v. Mapa, 20 SCRA 1164

T: Santayana y Escudero is hereby acquitted.

MJ:

MN: The law is explicit that it is unlawful for any person to possess any firearm, detached parts of
firearms or ammunition therefor, or any instrument or implement used or intended to be used in the
manufacture of firearms, parts of firearms, or ammunition ​(Sec 878 RA 4 of the RAC) except when
such firearms are in possession of such public officials and public servants for use in the performance
of their official duties; as those firearms and ammunitions which are regularly and lawfully issued to
officers, soldiers, sailors or marines, the Philippines Constabulary, guards in the employment of the
Bureau of Prisons, municipal police, provincial governors, lieutenant governors, provincial treasurers,
municipal treasurers, municipal mayors, and guards of provincial prisoners and jails ​(Sec 879)

CASE: Santiago v. COMELEC, 270 SCRA 106

T:

MJ: Statute must be capable of construction, otherwise it will be inoperative and void.

MN: In this case, the Court adopted a literal meaning thus, concluded that RA 6735 is inadequate to
implement the power of the people to amend the Constitution (initiative on amendments) for the
following reasons:

i. Does not suggest an initiative on amendments to the Constitution because it is silent as to

amendments on the Constitution and the word “Constitution” is neither germane nor relevant
to said section

ii Does not provide for the contents of a petition for initiative on the Constitution

iii. Does not provide for subtitles for initiative on the Constitution iv. RA is incomplete and
does not provide a sufficient standard

CASE: Matabuena v. Cervantes, 38 SCRA 284

WoN Art.133 of the Civil Code “Every donation between the spouses during the marriage
shall be void” extends to donations by live -in partners?

T: Yes it extend to donations by live -in partners

MJ: It is a principle of statutory construction that what is within the spirit of the law is as much a part
of it as what is written. If there is ever any occasion where the principle of statutory construction that
what is within the spirit of the law is as much a part of it as what is written, then such would be it.
Otherwise the basic purpose discernible in such codal provision would not be attained.

MN: The reason for the ban on donations between spouses during the marriage is to prevent the
possibility of undue influence and improper pressure being exerted by one spouse on the other, there
is no reason why this prohibition shall not apply also to common -law relationships. The court,
however, said that the lack of the donation made by the deceased to Respondent does not necessarily
mean that the Petitioner will have exclusive rights to the disputed property because the relationship
between Felix and Respondent were legitimated by marriage.

Furthermore, a 1954 Court of Appeals decision Buenaventura v. Bautista, interpreting a similar

provision of the old Civil Code says clearly that if the policy of the law is (in the language of the
opinion of the then Justice J.B.L. Reyes of that Court) "to prohibit donations in favor of the other
consort and his descendants because of fear of undue and improper pressure and influence upon the
donor, a prejudice is deeply rooted in our ancient law then there is every reason to apply the same
prohibitive policy to persons living together as husband and wife without benefit of nuptials.

King v. Hernandez, 114 SCRA 730

WoN a Chinese may be employed in a non -control position in a retail establishment, a

wholly nationalized business under RA 1180 Retail Trade Law?

T: No, a Chinese may not be employed in a non -control position in a retail establishment, a wholly
nationalized business under RA 1180 Retail Trade Law

MJ: It is a principle of statutory construction that what is within the spirit of the law is as much a part
of it as what is written. If there is ever any occasion where the principle of statutory construction that
what is within the spirit of the law is as much a part of it as what is written, then such would be it.
Otherwise the basic purpose discernible in such codal provision would not be attained.

MN: In this case, the law has to be construed with the Anti -Dummy Law – prohibiting an alien from
intervening in the management, operation, administration or control thereof . When the law says you
cannot employ such alien, you cannot employ an alien! The unscrupulous alien may resort to flout the
law or defeat its purpose. It is imperative that the law be interpreted in a manner that would stave off
any attempt at circumvention of the legislative purpose.

US v. Toribio, 15 Phil 85

T: The police power is valid.

MJ: Where the language of a statute is fairly susceptible of two or more constructions, that
construction should be adopted which will most tend to give effect to the manifest intent of the
lawmaker and promote the object for which the statute was enacted, and a construction should be
rejected which would tend to render abortive other provisions of the statute and to defeat the object
which the legislator sought to attain by its enactment.

MN: To ​follow the contention of Toribio it will defeat the purpose of the law. The police power rests
upon necessity and the right of self-protection and if ever the invasion of private property by police
regulation can be justified, The Supreme Court think that the reasonable restriction placed upon the
use of carabaos by the provision of the law under discussion must be held to be authorized as a
reasonable and proper exercise of that power.

The Supreme court finally said that article 1147 is not an exercise of the inherent power of eminent
domain. The said law does not constitute the taking of carabaos for public purpose; it just serve as a
mere regulation for the consumption of these private properties for the protection of general welfare
and public interest.

Bocobo v. Estanislao, 72 SCRA 520

WoN the CFI and a municipal court in the capital of the province have concurrent
jurisdiction over the crime of libel?

T: RTC has rightful jurisdiction of all libel cases, regardless of what form, thus it can be filed in any
municipal court where the libellous statement was made.

MJ: ​It is a principle of statutory construction that what is within the spirit of the law is as much a part
of it as what is written. If there is ever any occasion where the principle of statutory construction that
what is within the spirit of the law is as much a part of it as what is written, then such would be it.
Otherwise the basic purpose discernible in such codal provision would not be attained.

MN: In this case, the purpose of the law is to limit the choice of jurisdiction of the complainant. To
allow complainant of more choices of either the RTC or MTC, that would result to more inconvenience
on the part of the accused.

Planters Association of Negros, Inc. v. Ponferrada, G.R. No. 114087, October 26, 1999

MJ: Two conflicting provisions should be construed as to realize the purpose of the law.

MN: In this case, the purpose of the law is to INCREASE the workers’ benefits. The benefits under RA
6982 shall be considered IN ADDITION to the benefits under RA 809 and PD 621. Furthermore, the
word “substituted” cannot be given the literal interpretation.

CASE: Villanueva v. COMELEC, G.R. No. L-54718, December 4, 1985 (Read the dissent of Justice
Aquino for the caveat on this rule)

MJ: The intention controls the literal interpretation of a particular language of statute. ​Verba
intentioni, non e contra, debent inservire: words ought to be more subservient to the intent and not
the intent to the words. If there’s two conflicting theories, courts choose which best accords with the
spirit or intent of the law. Conscience and equity should always be considered in the construction of a
statute. The spirit and intention of the law must prevail over its letter.

MN: In this case, since the withdrawal of Mendoza occurred in the evening of the last day of filing of
the CoC, it should be deemed as if it was done, accepted, and approved the following day – thus the
withdrawal is to be considered valid as of the day following the last day of filing of CoC.

CASES: Comendador vs. De Villa, GR No. 93177, August 2, 1991

MJ: ​Ratio legis est anima:​ the reason of the law is its soul. The reason behind the law is the heart of
the law. Reason of the law plays a decisive role in its construction. A statute may render a prior law
devoid of reason. Where a later law has a purpose in conflict with that of a prior statute on the same
subject, the latter has lost all meaning and function and has ceased to exist.

MN: In this case, the termination of martial law and the dissolution of military tribunals created
thereunder, the reason of the existence of PD 39 ceased automatically and the decree itself ceased.