Title Facts Doctrine

Endencia vs. David Associate Justices of CA and SC filed a The collection of income tax on the salary
petition declaring RA No. 590 Sec. 13 of a judicial officer is a diminution thereof
unconstitutional and that they may be and so violates the Constitution. The
refunded the income tax collected on their
interpretation and application of the
salaries. Lower court that under the
Perfecto v. Meer doctrine, the collection Constitution and of statutes is within the
of income taxes on the salaries of public exclusive province and jurisdiction of the
officials was a diminution of their judicial department, and that in enacting a
compensation and therefore was in law, the Legislature may not legally
violation of the Constitution. Thereafter, provide therein that it be interpreted in
Congress promulgated RA No. 590 to such a way that it may not violate a
counteract the SC ruling and authorize
Constitutional prohibition, especially when
and legalize the collection of income tax
on the salaries of judicial officers. the interpretation sought and provided in
said statute runs counter to a previous
Issue: Whether or not the legislature may interpretation already given in a case.
lawfully declare the collection of income
tax on the salary of a public official,
especially a judicial officer, not a
decrease of his salary after the Supreme
Court has found and decided otherwise
Angara vs. COMELEC Jose Angara was proclaimed winner and
took his oath of office as member of the
National Assembly of the Commonwealth
Government. On December 3, 1935, the
National Assembly passed a resolution
confirming the election of those who have
not been subject of an election protest prior
to the adoption of the said resolution. On
December 8, 1935, however, private
respondent Pedro Ynsua filed an election
protest against the petitioner before the
Electoral Commission of the National
Assembly. The following day, December 9,
1935, the Electoral Commission adopted its
own resolution providing that it will not
consider any election protest that was not
submitted on or before December 9, 1935. 

Citing among others the earlier

resolution of the National Assembly, the
petitioner sought the dismissal of
respondent’s protest. The Electoral
Commission however denied his motion.