Espiritu vs Cipriano

G.R. No. 32743

February 15, 1974

Facts
  Petition filed in the Municipal Court of Pasig, Rizal, against private respondent Ricardo
Cipriano for the latter's alleged failure to pay rentals, on May 30, 1969. 
 Due to insufficient amount of time, the defendant was not able to disclose to his former
counsel all the material facts surrounding his case. Therefore, he was not able to fully
prepare his defenses.
  Before the hearing of the case in the lower court he wanted to cause the filing of an
amended answer but was not able to do so for his alleged failure to contact his counsel.  The
motion to file amended answer was denied by the Court. 
 The plaintiffs are the owners of the property in question, leased to the defendant since
1954;

 The house of the defendant was built on the property with the knowledge and consent of
the plaintiff pursuant to an oral contract of lease;
 Before 1969 the lease of the property was on year-to-year arrangement, rentals being then
payable at or before the end of the year;
 Effective January 1969 the lease was converted to a month-to-month basis and rental was
increased to P30.00 a month by the plaintiffs;
 The defendant has remained in possession of the property up to the present;
 Since January 1969 the defendant has not paid rental at the present monthly rate;
 A formal notice to vacate, dated March 22, 1969, was sent by registered mail to, and
received by, defendant.

Issues
 Whether or not to dismiss the order of the Court of First Instance of Rizal, Branch XV dated
August 4, 1970, sustaining private respondent Ricardo Cipriano's motion to dismiss "on the
authority of Republic Act 6126"
Ruling
 therefore, rule that Republic Act 6126 is not applicable to the case at bar.  As the language
of the law is clear and unambiguous, it must be held to mean what it plainly says.
 SC found the petition of spouses Espiritu meritorious, thus, reversing the trial court’s
decision and ordering the trial court for the prompt disposition of Civil Case No. 338-M on
the merits in accordance with RA. 6031
 Homeowners Assn. of the Phils. vs. Municipal Board of Manila
G.R. No. L-23979
August 30, 1968

Facts
 The lower court struck down the questioned ordinance upon the ground that the power to
"declare a state of emergency ... exclusively pertains to Congress"; that "there is no longer
any state of emergency" which may justify the regulation of house rentals;
 The people do not deem it necessary to pass upon these questions or upon the soundness
of the other points relied upon by His Honor, the trial Judge, on which they express here no
opinion whatsoever.
 The authorities used police power to regulate peace and order.

Issues
 In view of the prevailing scarcity of lands and buildings for residential purposes in the City of
Manila and the present high cost of living, a state of emergency in the the matter of
providing housing accommodations especially for poor at reasonable rates is hereby
declared to exist
 This is an action, against the Municipal Board and the Mayor of the City of Manila, for a
declaratory relief. It was brought by the Homeowners' Association of the Philippines, Inc.
and its President, Vicente A. Rufino, to nullify Municipal Ordinance No. 4841 of the City of
Manila.

Ruling

 Occena vs. COMELEC
95 SCRA 755
(1980)

Case 3
Facts
 January 15, 1980, after deliberating on the memoranda and arguments adduced by both
parties at the hearing, the Court finds no merit in the petition.
 The legislative power granted by Section 1, Article VIII of the Constitution to the National
Assembly has been explicitly vested during the period of transition on the Interim Batasang
Pambansa by Amendment No. 2 to the constitution.
 Petitioner's invocation of the Report of the Committee on Transitory Provisions of October
13, 1972 does not. support his contention that the Interim Batasang Pambansa has no
power to call local elections.
 The Filipino people rejected the convening of the interim National Assembly, and for a
perfectly justifiable reason.
 By the will of the people, as expressed overwhelmingly in the plebiscite of October 15 and
16, 1976, Amendments Nos. 1 to 9 were approved, abolishing the interim National Assembly
and creating in its stead an interim Batasang Pambansa.

Issues
 Does the interim Batasang Pambansa has the right to propose amendments?
Ruling
 The Interim of the Batasang Pambansa has the power to propose amendments. They have
the same function with the National Assembly which is to propose amendments vested by
the provisions of the 1976 amendments.
 Ople vs Torres
293 SCRA 141
(1998)

Facts
 December 12, 1996, President Fidel V. Ramos issued the Administrative Order No. 308
“Adoption of a National Computerized Identification Reference System”
 Senator Blas F. Ople filed a petition to invalidate A.O No. 308 because it is unconstitutional
usurpation of the legislative power of the congress.
 The respondents said that A.O No. 308 was issued by the power of the President without
even passing through the legislative power of the congress.
Issues
 Whether President Ramos’ issuance of Administrative Order No. 308 is unconstitutional use
of the power of Congress.
Ruling
 The executive power is vested in the president meaning, the president is the head of the
executive department, and the Chief Executive. The President has the power to enforce and
administer the law.
 The President has control over the executive department, and also granted administrative
power over bureaus and offices.
 With these examples, the president has the power to enforce and administer a law. That’s
why A.O No. 308 is valid, and the petition will be dismissed.
 Tolentino vs. Secretary of Finance
235 SCRA 630
(1994)

Facts
 RA 7716, otherwise known as the Expanded Value-Added Tax Law, is an act that seeks to
widen the tax base of the existing VAT system and enhance its administration by amending
the National Internal Revenue Code. There are various suits questioning and challenging the
constitutionality of RA 7716 on various grounds.
 Tolentino is stating that RA. 7716 did not come from the House of Representatives but is a
mere consolidation of HB. No. 11197 and SB. No. 1630 and wasn’t able to pass three
readings on the Senate which violates Article VI, Section 24 and 26 of the Constitution,
respectively
 Art. VI, Section 24: All appropriation, revenue or tariff bills, bills authorizing increase of the
public debt, bills of local application, and private bills shall originate exclusively in the House
of Representatives, but the Senate may propose or concur with amendments.
 Art. VI, Section 26(2): No bill passed by either House shall become a law unless it has
passed three readings on separate days, and printed copies thereof in its final form have
been distributed to its Members three days before its passage, except when the President
certifies to the necessity of its immediate enactment to meet a public calamity or
emergency. Upon the last reading of a bill, no amendment thereto shall be allowed, and the
vote thereon shall be taken immediately thereafter, and the yeas and nays entered in the
Journal.
Issues
 If RA 7716 violated Art. VI, Section 24 and Art. VI, Section 26(2) of the Constitution
Ruling
 No. Due to the phrase “originate exclusively” which pertains to the revenue bill, not the
revenue law. The House of Representatives is enough to initiate the passage of the bill
which may undergo extensive changes in the senate

SB. No. 1630, having been certified as urgent by the President need not meet the
requirement not only of printing but also of reading the bill on separate days.