Edencia and Jugo v David,etc Legislative Branch – assigned the power to make

Nos. L-6355-56 | Aug 31, 1953 | Montemayor and enact laws.

Facts: Executive Branch – charged with the execution

 There are two contradicting provisions in or carrying out the provisions of said laws.
this case:
 Sec 9, Art VIII of the Constitution: “ Judiciary – Interpretation and application of laws.
The members of the Supreme Court
and all judges of inferior courts… x x Thus, in this case, the act of interpretating
x They shall receive such the Constitution or any part thereof by the
compensation as may be fixed by the Legislature is an invasion of the well-defined
law, which shall not be diminished and established province and jurisdiction of
during their continuance in office. the Judiciary. The court has already said that the
 RA 590: “No salary wherever Legislature under our form of government is
received by any public officer of the assigned the task and the power to make and
Republic of the Philippines shall be enact laws, but not ti interpret them.
considered as exempt from the If the legislature may declare what a law
income tax, payment of which is means, or what specific portion of the
hereby declared not to be a Constitution means, especially after the courts
diminution of his compensation fixed have in actual case ascertain its meaning by
by the Constitution or by law” interpretation and applied it in a decision, this
 The SC in a decision interpreting the would surely cause confusion and instability in
Constitution, particularly Sec 9 of Art judicial processes and court decisions.
VIII, has held that judicial officers are
exempt from the payment of income tax
on their salaries, because the collection
thereof was a diminution of such salaries,
specifically prohibited by the
Constitution.
 However, the legislature in Sec 13 of RA
590 says that every public officer,
naturally including a judicial officer, shall
not be exempted from income tax. And
they interpret it as not a diminution in
compensation

Issue:
Can the legislature lawfully declare the
collection of income tax on the salary of a
judicial officer not a decrease of his salary,
AFTER THE SC HAS FOUND AND
DECIDED OTHERWISE?

Held:
No, it is not part of the power vested in the
legislative branch to do so.

To resolve the issue, we should go back to

the fundamental principles regarding separation
of powers.