Statutory Construction

Specific Cases
Aequetas nunquam contravenit legis
 Laches is a doctrine in equity while prescription is
based on law. Our courts are basically courts of
law and not courts of equity. Thus, laches cannot
be invoked to resist the enforcement of an
existing legal right. We have ruled in Arsenal v.
Intermediate Appellate Court . . . that it is a long
standing principle that equity follows the law.
Courts exercising equity jurisdiction are bound
by rules of law and have no arbitrary discretion to
disregard them. In Zabat, Jr. v. Court of Appeals . .
., this Court was more emphatic in upholding the
rules of procedure. We said therein:
Aequetas nunquam contravenit legis
 As for equity, which has been aptly described as
"justice outside legality," this is applied only in the
absence of, and never against, statutory law or, as
in this case, judicial rules of procedure. Aequetas
nunquam contravenit legis. This pertinent positive
rules being present here, they should preempt
and prevail over all abstract arguments based only
on equity.

 Thus, where the claim was filed within the three-

year statutory period, recovery therefore cannot
be barred by laches.
Applicability to Labor Contracts
 Can the Rules on Statutory Construction
be applied to Labor Contacts?

 Del Monte Fresh Produce Inc. vs. Del

Monte Fresh Supervisors Union, G.R. No.
225115, Jan. 27, 2020
Applicability to Labor Contracts
Applicability to Labor Contracts
Centeno vs.Villalon, et al. G.R. No. 113092, Sept. 1, 1994

 Presidential Decree No. 1564 (which amended Act No. 4075,

otherwise known as the Solicitation Permit Law), provides as
follows:

 Sec. 2. Any person, corporation, organization, or association desiring

to solicit or receive contributions for charitable or public welfare
purposes shall first secure a permit from the Regional Offices of
the Department of Social Services and Development as provided in
the Integrated Reorganization Plan. Upon the filing of a written
application for a permit in the form prescribed by the Regional
Offices of the Department of Social Services and Development, the
Regional Director or his duly authorized representative may, in his
discretion, issue a permanent or temporary permit or disapprove
the application. In the interest of the public, he may in his discretion
renew or revoke any permit issued under Act 4075.
Centeno vs.Villalon, et al. G.R. No. 113092, Sept. 1, 1994

 The main issue to be resolved here is whether the

phrase "charitable purposes" should be construed in its
broadest sense so as to include a religious purpose. We
hold in the negative.
 I. Indeed, it is an elementary rule of statutory
construction that the express mention of one person,
thing, act, or consequence excludes all others. This rule
is expressed in the familiar maxim "expressio unius est
exclusio alterius." Where a statute, by its terms, is
expressly limited to certain matters, it may not, by
interpretation or construction, be extended to others.
The rule proceeds from the premise that the legislature
would not have made specified enumerations in a
statute had the intention been not to restrict its meaning
and to confine its terms to those expressly mentioned. 7
Centeno vs.Villalon, et al. G.R. No. 113092, Sept. 1, 1994

 That these legislative enactments specifically

spelled out "charitable" and "religious" in an
enumeration, whereas Presidential Decree No.
1564 merely stated "charitable or public welfare
purposes," only goes to show that the framers of
the law in question never intended to include
solicitations for religious purposes within its
coverage. Otherwise, there is no reason why it
would not have so stated expressly.
People vs. Ladjaalam, G.R. No. 136149-51, Sept. 19, 2000

 "Section 1. Unlawful Manufacture, Sale, Acquisition,

Disposition or Possession of Firearms or Ammunition
Instruments Used or Intended to be Used in the
Manufacture of Firearms or Ammunition. -- The penalty of
prision correccional in its maximum period and a fine of
not less than Fifteen thousand pesos (₱15,000) shall be
imposed upon any person who shall unlawfully
manufacture, deal in, acquire, dispose, or possess any
low powered firearm, such as rimfire handgun, .380 or
.32 and other firearm of similar firepower, part of
firearm, ammunition, or machinery, tool or instrument
used or intended to be used in the manufacture of any
firearm or ammunition: Provided, That no other crime
was committed.
People vs. Ladjaalam, G.R. No. 136149-51, Sept. 19, 2000

 Moreover, penal laws are construed liberally in favor of

the accused. In this case, the plain meaning of RA 8294’s
simple language is most favorable to herein appellant.
Verily, no other interpretation is justified, for the
language of the new law demonstrates the legislative
intent to favor the accused. Accordingly, appellant
cannot be convicted of two separate offenses of illegal
possession of firearms and direct assault with attempted
homicide. Moreover, since the crime committed was
direct assault and not homicide or murder, illegal
possession of firearms cannot be deemed an aggravating
circumstance. Provided, that no other crime was
committed.
People vs. Ladjaalam, G.R. No. 136149-51, Sept. 19, 2000

 The Court is aware that this ruling effectively exonerates appellant

of illegal possession of an M-14 rifle, an offense which normally
carries a penalty heavier than that for direct assault. While the
penalty for the first is prision mayor, for the second it is only prision
correccional. Indeed, the accused may evade conviction for illegal
possession of firearms by using such weapons in committing an
even lighter offense, like alarm and scandal or slight physical injuries,
both of which are punishable by arresto menor. This consequence,
however, necessarily arises from the language of RA 8294, whose
wisdom is not subject to the Court’s review. Any perception that
the result reached here appears unwise should be addressed to
Congress. Indeed, the Court has no discretion to give statutes a
new meaning detached from the manifest intendment and language
of the legislature. Our task is constitutionally confined only to
applying the law and jurisprudence to the proven facts, and we have
done so in this case.
Misamis Oriental Assn. of Coco Traders vs. DOF, et al., G.R. No.
108524, Nov. 10, 1994

 Sec. 103. Exempt Transactions. — The following

shall be exempt from the value-added tax:

 (a) Sale of nonfood agricultural, marine and forest

products in their original state by the primary
producer or the owner of the land where the
same are produced;

 (b) Sale or importation in their original state of

agricultural and marine food products, livestock
and poultry of a kind generally used as, or yielding
or producing foods for human consumption, and
breeding stock and genetic material therefor;
Misamis Oriental Assn. of Coco Traders vs. DOF, et al., G.R. No.
108524, Nov. 10, 1994

 Accordingly, in considering a legislative rule a court is free to

make three inquiries: (i) whether the rule is within the
delegated authority of the administrative agency; (ii) whether
it is reasonable; and (iii) whether it was issued pursuant to
proper procedure. But the court is not free to substitute its
judgment as to the desirability or wisdom of the rule for the
legislative body, by its delegation of administrative judgment,
has committed those questions to administrative judgments
and not to judicial judgments. In the case of an interpretative
rule, the inquiry is not into the validity but into the
correctness or propriety of the rule. As a matter of power a
court, when confronted with an interpretative rule, is free to
(i) give the force of law to the rule; (ii) go to the opposite
extreme and substitute its judgment; or (iii) give some
intermediate degree of authoritative weight to the
interpretative rule.
Misamis Oriental Assn. of Coco Traders vs. DOF, et al., G.R. No.
108524, Nov. 10, 1994

 Accordingly, in considering a legislative rule a court is

free to make three inquiries: (i)
 In the case at bar, we find no reason for holding that
respondent Commissioner erred in not considering
copra as an "agricultural food product" within the
meaning of § 103(b) of the NIRC. As the Solicitor
General contends, "copra per se is not food, that is, it
is not intended for human consumption. Simply
stated, nobody eats copra for food." That previous
Commissioners considered it so, is not reason for
holding that the present interpretation is wrong. The
Commissioner of Internal Revenue is not bound by
the ruling of his predecessors. To the contrary, the
overruling of decisions is inherent in the
interpretation of laws.
Misamis Oriental Assn. of Coco Traders vs. DOF, et al., G.R. No.
108524, Nov. 10, 1994

 Fourth. It is finally argued that RMC No. 47-91 is

counterproductive because traders and dealers would be
forced to buy copra from coconut farmers who are exempt
from the VAT and that to the extent that prices are reduced
the government would lose revenues as the 10% tax base is
correspondingly diminished.

 This is not so. The sale of agricultural non-food products is

exempt from VAT only when made by the primary producer
or owner of the land from which the same is produced, but
in the case of agricultural food products their sale in their
original state is exempt at all stages of production or
distribution. At any rate, the argument that the classification
of copra as agricultural non-food product is
counterproductive is a question of wisdom or policy which
should be addressed to respondent officials and to Congress.
Erectors Inc. vs. NLRC, G.R. No. 104205, May 8, 1996

 The case of Briad Agro Development Corp. vs. Dela Cerna 14 cited by the
petitioner is not applicable to the case at bar. In Briad, the Court applied
the exception rather than the general rule. In this case, Briad Agro
Development Corp. and L.M. Camus Engineering Corp. challenged the
jurisdiction of the Regional Director of the Department of Labor and
Employment over cases involving workers' money claims, since Article 217
of the Labor Code, the law in force at the time of the filing of the
complaint, vested in the Labor Arbiters exclusive jurisdiction over such
cases. The Court dismissed the petition in its Decision dated June 29, 1989.
15 It ruled that the enactment of E.O. No. 111, amending Article 217 of the
Labor Code, cured the Regional Director's lack of jurisdiction by giving the
Labor Arbiter and the Regional Director concurrent jurisdiction over all
cases involving money claims. However, on November 9, 1989, the Court,
in a Resolution, 16 reconsidered and set aside its June 29 Decision and
referred the case to the Labor Arbiter for proper proceedings, in view of
the promulgation of Republic Act (R.A.) 6715 which divested the Regional
Directors of the power to hear money claims. It bears emphasis that the
Court accorded E.O. No. 111 and R.A. 6715 a retroactive application
because as curative statutes, they fall under the exceptions to the rule on
prospectivity of laws.
Erectors Inc. vs. NLRC, G.R. No. 104205, May 8, 1996

 The law at bar, E.O. No. 797, is not a curative statute.

It was not intended to remedy any defect in the law.
It created the POEA to assume the functions of the
Overseas Employment Development Board, the
National Seamen Board and the overseas
employment functions of the Bureau of Employment
Services. Accordingly, it gave the POEA "original and
exclusive jurisdiction over all cases, including money
claims, involving employer-employee relations arising
out of or by virtue of any law or contract involving
Filipino workers for overseas employment, including
seamen." 17 The rule on prospectivity of laws should
therefore apply to E.O. No. 797. It should not affect
jurisdiction over cases filed prior to its effectivity.
Erectors Inc. vs. NLRC, G.R. No. 104205, May 8, 1996

 Article 217 of the Labor Code – Jurisdiction of the

Labor Arbiter
 E.O. No. 797-Created the POEA
 E.O. No. 111-Gave LA and RDs concurrent jurisdiction
 RA No. 6715-Cured the confusion
 PD No. 1391-Amended PD No. 442 - Jurisdcition
 PD No. 1691-Amended PD No. 442- Created the
OEDB
Ong Chia vs. Republic, G.R. No. 127240, March 27, 2000

 Rule 132 on Evidence

 Cannot consider evidence not presented
during the trial
 Not absolute, subject to exceptions
 Petitioner was not deprived of his right to
object
Ong Chia vs. Republic, G.R. No. 127240, March 27, 2000

 Prescinding from the above, the rule on formal offer of

evidence (Rule 132, 34) now being invoked by petitioner is
clearly not applicable to the present case involving a petition
for naturalization. The only instance when said rules may be
applied by analogy or suppletorily in such cases is when it is
"practicable and convenient." That is not the case here, since
reliance upon the documents presented by the State for the
first time on appeal, in fact, appears to be the more practical
and convenient course of action considering that decisions in
naturalization proceedings are not covered by the rule on
res judicata. 14 Consequently, a final favorable judgment does
not preclude the State from later on moving for a revocation
of the grant of naturalization on the basis of the same
documents.
Ong Chia vs. Republic, G.R. No. 127240, March 27, 2000

 It is settled, however, that naturalization laws

should be rigidly enforced and strictly construed
in favor of the government and against the
applicant. 22 As noted by the State, C.A. No. 473,
7 clearly provides that the applicant for
naturalization shall set forth in the petition his
present and former places of residence. 23 This
provision and the rule of strict application of the
law in naturalization cases defeat petitioner's
argument of "substantial compliance" with the
requirement under the Revised Naturalization
Law
Resins Inc. vs. Auditor General, et al., No. L-17888, Oct. 29, 1968

 Petitioner seeks a refund from respondent Central Bank on

the claim that it was exempt from the margin fee under
Republic Act No. 2609 for the importation of urea and
formaldehyde, as separate units, used for the production of
synthetic glue of which it was a manufacturer.
 Specific language of the Act speak of "urea formaldehyde”
 Bill - urea and formaldehyde
 The enrolled bill which uses the term 'urea formaldehyde'
instead of 'urea and formaldehyde' is conclusive upon the
courts as regards the tenor of the measure passed by
Congress and approved by the President
Resins Inc. vs. Auditor General, et al., No. L-17888, Oct. 29, 1968

 Then, again, there is merit in the contention of the Solicitor

General, as counsel for respondent Central Bank, and the Auditor
General, that as a refund undoubtedly partakes of a nature of an
exemption, it cannot be allowed unless granted in the most explicit
and categorical language. As was held by us in Commissioner of
Internal Revenue vs. Guerrero:5 "From 1906, in Catholic Church vs.
Hastings to 1966, in Esso Standard Eastern, Inc. vs. Acting
Commissioner of Customs, it has been the constant and uniform
holding that exemption from taxation is not favored and is never
presumed, so that if granted it must be strictly construed against
the taxpayer. Affirmatively put, the law frowns on exemption from
taxation, hence, an exempting provision should be construed
strictissimi juris." Certainly, whatever may be said of the statutory
language found in Republic Act 2609, it would be going too far to
assert that there was such a clear and manifest intention of
legislative will as to compel such a refund.