Item I: CASE DIGESTS

Aquino v. Quezon City

G.R. No. 137534, March 3, 2006
J. Azcuna

FACTS:
This case involves two petitions for review on certiorari involving the decisions declaring valid
the auction sales of two real properties by the Quezon City Local Gov’t for failure to pay real
property taxes.
The first case deals with a lot formerly owned by petitioners Aquino. Petitioners withheld
payment of the real property taxes as a form of protest for the gov’t of then President
Marcos. As a result of the nonpayment, the property was sold by the Quezon City local
government, through the Treasurer’s Office, at public auction to private respondent Aida
Linao, the highest bidder. Petitioners claimed that they learned of the sale about 2 years
later. They fixed as action for annulment of title, reconveyance, and damages against the
respondents.
The seconds case deals with a property located In Cubao, Quezon City in the name of
Solomon Torrado. According to petitioner heirs, Torrado paid taxes on the improvements on
Lot 8 but not on the lot itself because the Treasurer’s Office could not locate the index card
for that property. For failure to pay real property taxes from 1976 to 1982, the City Treasurer
sent a Notice of Intent to Sell to Torrado to his address indicated in the tax register, which
simply states as ‘ButuanCity. The notice was returned by reason of ‘Insufficient Address. Next
sent was a Notice of Sale of Delinquent Property. This was sent to the same address and
similarly returned unclaimed. Thereafter, a public auction was held and the lot was sold to
Veronica Baluyot, who mortgaged the property to Spouses Uy who then sold it to DNX Corp
for failure to pay the mortgaged debt. Also, a Notice of Sold Property was subsequently sent
to Torrado which was returned unclaimed.

ISSUE:
Whether there was a failure on the part of the Quezon City Local Government to satisfy the
notice requirements before selling the property for tax delinquency.

RULING:
No. There was no a failure on the part of the Quezon City Local Government to satisfy the
notice requirements before selling the property for tax delinquency. Definitely, there is no
more logical way to construe the whole chapter on ‘Collection of Real Property Tax (Sections
56 to 85) than to stress that while three methods are provided to enforce collection on real
property taxes, a notice of delinquency is a requirement regardless of the method or
methods chosen.

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It is incorrect for the respondents to claim that notice of delinquency has limited application
only to distrait of personal property. They mistakenly lumped Section 65 exclusively with
Sections 68 to 72 and, in so doing, restricted its application from the other tax remedies.
Section 65 is to be construed together with Sections 66 and 78 and all three operate in
reference to tax methods in general.
Petitioners are correct in insisting that two notices must be sent to the taxpayer concerned.
Nevertheless, respondents still prevail because the Court is satisfied that the two-notice
requirement has been complied with by the Treasurer’s Office.
WHEREFORE, both petitions are DENIED and the decisions of the Court of Appeals in CA-G.R.
CV Nos. 37487 and 49241 are AFFIRMED.
PRINCIPLE:
A rule of statutory construction is that a statute must be construed as a whole. The meaning
of the law is not to be extracted from a single part, portion or section or from isolated words
and phrases, clauses or sentences, but from a general consideration or view of the act as a
whole. Every part of the statute must be interpreted with reference to the context.

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 Gaanan v. Intermediate Appellate Court
G.R. No. L-69809, October 16, 1986
J. Azcuna

FACTS:
This case is a direct assault case against Leonardo Laconico which was filed by complainant
Atty. Tito Pintor and his client Manuel Montebon. The said complainants made a telephone
call to Laconico to give their terms for withdrawal of their complaint.
Laconico, later on, called appellant Gaanan, who is also a lawyer, to come to his office to
advise him about the proposed settlement. When complainant called up, Laconico requested
appellant to secretly listen to the telephone conversation through a telephone extension so
as to hear personally the proposed conditions for the settlement. After enumerating the
conditions, several calls were made to finally confirm if the settlement is agreeable to both
parties.
As part of their agreement, Laconico has to give the money to the complainant's wife at the
office of the Department of Public Highways. But, he insisted to give the money to the
complainant himself.
After receiving the money, the complainant was arrested by the agents of the Philippine
Constabulary, who were alerted earlier before the exchange.
Appellant stated on his affidavit that he heard complainant demand P8,000.00 for the
withdrawal of the case for direct assault. Laconico attached the affidavit of appellant to the
complainant for robbery/extortion which he filed against the complainant.
In defense, complainant charged appellant and Laconico with violation of the Anti-
Wiretapping Act as the appellant heard the telephone conversation without complainant's
consent.
The Trial Court ruled that both Gaanan and Laconico were guilty of violating Sect. 1 of RA No.
4200.
The Intermediate Appellate Court affirmed the decision of the Trial Court.
Hence, this petition. The case at bar involves an interpretation of the Republic Act No. 4200
or also known as Anti-Wiretapping Act. Petitioner contends that telephones or extension
telephones are not included in the enumeration of "commonly known" listening or recording
devices, nor do they belong to the same class of enumerated electronic devices
contemplated by law.
However, respondent argues that an extension telephone is embraced and covered by the
term "device" within the context of the aforementioned law because it is not a part or
portion of a complete set of a telephone apparatus.
ISSUE:

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Whether an extension telephone is among the prohibited devices in Section 1 of the Act,
such that its use to overhear a private conversation would constitute unlawful interception
of communications between the two parties using a telephone line.
RULING:
No. Under the Section 1 of Republic Act No. 4200 states that “It shall be unlawful for any
person, not being authorized by all the parties to any private communication or spoken
word, to tap any wire or cable, or by using any other device or arrangement, to secretly
overhear, intercept, or record such communication or spoken word by using a device
commonly known as a dictaphone or dictagraph or dictaphone or walkie-talkie or tape
recorder, or however otherwise described.”
It shall also be unlawful for any person, be he a participant or not in the act or acts penalized
in the next preceding sentence, to knowingly possess any tape record, wire record, disc
record, or any other such record, or copies thereof, of any communication or spoken word
secured either before or after the effective date of this Act in the manner prohibited by this
law; or to replay the same for any other person or persons; or to communicate the contents
thereof, either verbally or in writing, or to furnish transcriptions thereof, whether complete
or partial, to any other person: Provided, That the use of such record or any copies thereof as
evidence in any civil, criminal investigation or trial of offenses mentioned in section 3 hereof,
shall not be covered by this prohibition.
The law refers to a "tap" of a wire or cable or the use of a "device or arrangement" for the
purpose of secretly overhearing, intercepting, or recording the communication. There must
be either a physical interruption through a wiretap or the deliberate installation of a device
or arrangement in order to overhear, intercept, or record the spoken words.
An extension telephone cannot be placed in the same category as a dictaphone, dictagraph
or the other devices enumerated in Section 1 of RA No. 4200 as the use thereof cannot be
considered as "tapping" the wire or cable of a telephone line.
Hence, the phrase "device or arrangement", although not exclusive to that enumerated
therein, should be construed to comprehend instruments of the same or similar nature, that
is, instruments the use of which would be tantamount to tapping the main line of a
telephone. It refers to instruments whose installation or presence cannot be presumed by
the party or parties being overheard because, by their very nature, they are not of common
usage and their purpose is precisely for tapping, intercepting or recording a telephone
conversation.
WHEREFORE, the petition is GRANTED. The decision of the then Intermediate Appellate
Court dated August 16, 1984 is ANNULLED and SET ASIDE. The petitioner is hereby
ACQUITTED of the crime of violation of Rep. Act No. 4200, otherwise known as the Anti-
Wiretapping Act.
PRINCIPLE:
It is a rule in statutory construction that in order to determine the true intent of the
legislature, the particular clauses and phrases of the statute should not be taken as detached

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and isolated expressions, but the whole and every part thereof must be considered in fixing
the meaning of any of its parts.

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 Sajonas v. Court of Appeals
G.R. No. 102377, July 5, 1996
J. Torres Jr.

FACTS
This case was about when the spouses Ernesto Uychocde and Lucita Jarin agreed to sell a
parcel of residential land located in Antipolo, Rizal to the spouses Alfredo Sajonas and
Conchita R. Sajonas. On August 27, 1984, the Sajonas couple caused the annotation of an
adverse claim based on the said Contract to Sell on the title of the subject property. Upon full
payment of the purchase price, the Uychocdes executed a Deed of Sale involving the
property in question in favor of the Sajonas couple on September 4, 1984. The deed of
absolute sale was registered almost a year after, or on August 28, 1985.
Meanwhile, it appears that Domingo Pilares (defendant-appellant) filed for collection of sum
of money against Ernesto Uychocdes. When Uychocdes failed to comply with his undertaking
in the compromise agreement, defendant-appellant Pilares moved for the issuance of a writ
of execution. Accordingly, a writ of execution was issued on August 12, 1982. A notice of levy
on execution was issued and on February 12, 1985, defendant sheriff Roberto Garcia of
Quezon City presented said notice of levy on execution before the Register of Deeds of
Marikina and the same was annotated at the back of the title of subject property.
When the deed of absolute sale dated September 4, 1984 was registered on August 28,
1985, the notice of levy on execution annotated by defendant sheriff was carried over to the
new title. On October 21, 1985, the Sajonas couple filed a Third Party Claim with the sheriff
of Quezon city, hence the auction sale of the subject property did not push through as
scheduled.
On January 10, 1986, the Sajonas spouses demanded the cancellation of the notice of levy on
execution upon defendant-appellant Pilares, but Pilares refused to cause the cancellation of
said annotation.
Sajonas alleged that at the time the notice of levy was annotated by the defendant, the
Uychocdes spouses, debtors of the defendant, have already transferred, conveyed and
assigned all their title, rights and interests to the plaintiffs and there was no more title, rights
or interests therein which the defendant could levy upon; and that the annotation of the levy
on execution which was carried over to the title of said plaintiffs is illegal and invalid and was
made in utter bad faith, in view of the existence of the Adverse Claim annotated by the
plaintiffs on the corresponding title of the Uychocdes spouses.
Pilares contended that assuming without however admitting that they filed an adverse claim
against the property covered by TCT No. 79073 registered under the name of spouses
Ernesto Uychocdes on August 27, 1984, the same ceases to have any legal force and effect
(30) days thereafter pursuant to Section 70 of P.D. 1529; and that assuming without
admitting that the property subject matter of this case was in fact sold by the registered
owner in favor of the herein plaintiffs, the sale is the null and void (sic) and without any legal
force and effect because it was done in fraud of a judgment creditor, the defendant Pilares.

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The RTC ruled in favor of the Sajonas couple, and ordered the cancellation of the Notice of
Levy from Transfer Certificate of Title No. N-109417. The Court of Appeals: reversed the
lower court's decision, and upheld the annotation of the levy on execution on the certificate
of title.
The appellate court relied on the rule of statutory construction that Section 70 is specific and
unambiguous and hence, needs no interpretation nor construction. Perforce, the appellate
court stated, the provision was clear enough to warrant immediate enforcement, and no
interpretation was needed to give it force and effect. A fortiori, an adverse claim shall be
effective only for a period of thirty (30) days from the date of its registration, after which it
shall be without force and effect.
ISSUE:
Whether the adverse claim was still in force when private respondent caused the notice of
levy on execution to be registered and annotated in the said title, considering that more than
thirty days had already lapsed since it was annotated.
RULING:
Yes, the adverse claim was still in force when private respondent caused the notice of levy on
execution to be registered and annotated in the said title.
Concededly, annotation of an adverse claim is a measure designed to protect the interest of
a person over a piece of real property where the registration of such interest or right not
otherwise provided for by the Land Registration Act or Act 496 (now P.D. 1529 or the
Property Registration Decree), and serves a warning to third parties dealing with said
property that someone is claiming an interest on the same or a better right than that of the
registered owner thereof.
If the adverse claim was still in effect, then respondents are charged with knowledge of pre-
existing interest over the subject property, and thus, petitioners are entitled to the
cancellation of the notice of levy attached to the certificate of title. Section 70 of P.D. 1529
provides:
Section 70. Adverse Claim - Whoever claims any part or interest in registered land adverse to
the registered owner, arising subsequent to the date of the original registration, may, if no
other provision is made in this decree for registering the same, make a statement in writing
setting forth fully his alleged right or interest, and how or under whom acquired, a reference
to the number of certificate of title of the registered owner, the name of the registered
owner, and a description of the land in which the right or interest is claimed.
In ascertaining the period of effectivity of an inscription of adverse claim, we must read the
law in its entirety. Construing the provision as a whole would reconcile the apparent
inconsistency between the portions of the law such that the provision on cancellation of
adverse claim by verified petition would serve to qualify the provision on the effectivity
period. The law, taken together, simply means that the cancellation of the adverse claim is
still necessary to render it ineffective, otherwise, the inscription will remain annotated and
shall continue as a lien upon the property. For if the adverse claim has already ceased to be

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effective upon the lapse of said period, its cancellation is no longer necessary and the
process of cancellation would be a useless ceremony.
To interpret the effectivity period of the adverse claim as absolute and without qualification
limited to thirty days defeats the very purpose for which the statute provides for the remedy
of an inscription of adverse claim, as the annotation of an adverse claim is a measure
designed to protect the interest of a person over a piece of real property where the
registration of such interest or right is not otherwise provided for by the Land Registration
Act or Act 496 (now P.D. 1529 or the Property Registration Decree), and serves as a warning
to third parties dealing with said property that someone is claiming an interest or the same
or a better right than the registered owner thereof.
ACCORDINGLY, the assailed decision of the respondent Court of Appeals dated October 17,
1991 is hereby REVERSED and SET ASIDE. The decision of the Regional Trial Court dated
February 15, 1989 finding for the cancellation of the notice of levy on execution from
Transfer Certificate of Title No. N-109417 is hereby REINSTATED.
The inscription of the notice of levy on execution on TCT No. N-109417 is hereby CANCELLED
PRINCIPLE:
A statute is passed as a whole and not in parts sections, and is animated by one general
purpose and intent. Consequently, each part or section should be construed in connection
with every other part section so as to produce a harmonious whole. It is not proper to
confine its intention to the one section construed. It is always an unsafe way of construing a
statute or contract to divide it by a process of etymological dissection, into separate words,
and then apply to each, thus separated from the context, some particular meaning to be
attached to any word or phrase usually to be ascertained from the as context.

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 Cuyegkeng, et al. v. Cruz
G.R. No. L-16263, July 26, 1960
J. Concepcion

FACTS:
The petitioners are doctors Jose Cuyegkeng, Pedro N. Mayuga, Benjamin Roa, Timoteo Alday,
Dominador Jacinto, Alejandro Gaerlan and Rosita Rivera-Ramirez. Their alleged cause of
action is predicated upon the fact that their names appear in a list of qualified physicians,
approved and submitted, to the President of the Philippines, by the Executive Council of the
Philippine Medical Association of the Philippines pursuant to the provisions of section 13 of
Republic Act No. 2382, for appointment as members of the Board of Medical Examiners, and
that respondent Dr. Pedro M. Cruz, whom the President appointed to said board was not
named in said list.
Soon after the institution of this case, the officers and members of said Council of the
Philippine Medical Association, which is said to be an incorporated association of the medical
profession in the Philippines, were allowed to intervene and then filed a petition in
intervention, joining the petitioners in praying for the relief sought by them.
ON THE FIRST OF ACTION:
1. Declaring the petitioners as duly qualified for the position of member of the Board of
Medical Examiners and that any one of them is legally entitled to be appointed as members
of said Board;
2. Declaring the appointment of the respondent Dr. Pedro M. Cruz as members of the Board
of Medical Examiners illegal and therefore null and void and ousting him therefrom and
perpetually prohibiting him (unless appointed in accordance with law) from exercising the
rights and performing the duties and functions connected therewith.
ON THE SECOND CAUSE OF ACTION:
1. That pending the hearing on the merits of this case a writ of preliminary injunction be
issued forthwith ex parte ordering the respondent to cease, desist and refrain from assuming
the office of member of the Board of Medical Examiners and exercising the rights and
performing the duties and functions connected therewith, particularly to give or conduct the
next examinations for physicians scheduled on or about December 14, 1959, or to take part
in any way in the giving or conducting thereof, and after due hearing to make said injunction
permanent;
2. Ordering the respondent to pay the costs of this suit.
Petitioners further pray for such further and other relief as this Honorable Court "may deem
just and proper under the premises."
By a resolution dated December 3, 1959, this Court denied the petition for a writ of
preliminary injunction.
ISSUE:

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Whether the appointment of respondent herein lawful and valid.
RULING:
Yes. The Court Ruled that Respondent has a good and valid right to his title on the grounds
that one who does not claim to be entitled to the office allegedly usurped or unlawfully held
or exercised by another cannot question his title thereto by quo warranto. In the case at bar,
petitioners do not claim to entitled to the office held by respondent herein. None of them
has been appointed thereto and none of them may, therefore, be placed in said office,
regardless of the alleged flaws in respondent's title thereto. They merely assert a right to be
appointed to said office. Considering, however, that there are seven (7) petitioners and that
only one (1) office is involved in this case, none of them can, or does, give an assurance that
he will be the one appointed by the President, should said office be declared vacant. In short,
the claim of each petitioner is predicated solely upon a more or less recipient of the
appointment. It is obvious, therefore, that none of them has a cause of action against
respondent herein.
PRINCIPLE:
The authority of the chief executive of those states to appoint the officers involved in said
cases springs mostly from statutes, unlike the President of the Philippines, whose appointing
power emanates from our Constitution.

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 Manila Lodge No. 761 v. Court of Appeals
G. R. No. L-41001 September 30, 1976
J. Castro

FACTS:
This case are petitions on certiorari to review the decision dated June 30, 1975 of the Court
of Appeals in CA-G.R. No. 51590-R entitled "Tarlac Development Corporation vs. City of
Manila, and Manila Lodge No. 761, Benevolent and Protective Order of Elks, Inc., affirming
the trial court's finding in Civil Case No. 83009 that the property subject of the decision a quo
is a "public park or plaza."
On June 26, 1905 the Philippine Commission enacted Act No. l360 which authorized the City
of Manila to reclaim a portion of Manila Bay. The reclaimed area was to form part of the
Luneta extension. The Act provided that the reclaimed area "Shall be the property of the City
of Manila" and that "the City of Manila is hereby authorized to set aside a tract of the
reclaimed land formed by the Luneta extension x x x at the north end not to exceed five
hundred feet by six hundred feet in size, for a hotel site, and to lease the same, with the
approval of the Governor General, to a responsible person or corporation for a term not
exceed ninety-nine years."
Subsequently, the Philippine Commission passed on May 18, 1907 Act No. 1657, amending
Act No. 1360, so as to authorize the City of' Manila either to lease or to sell the portion set
aside as a hotel site.
On July 13, 1911 the City of Manila, affirming a prior sale dated January 16, 1909 cancelled
5,543.07 square meters of the reclaimed area to the Manila Lodge No. 761, Benevolent and
Protective Order of Elks of the U.S.A. (BPOE, for short) on the basis of which TCT No. 2195 2
was issued to the latter over the Marcela de terreno que es parte de la Luneta Extension,
Situada en el Distrito le la Ermita." At the back of this title vas annotated document 4608/T-
1635, which in part reads as follows: "que la citada Ciusdad de Manila tendra derecho a su
opcion, de recomparar la expresada propiedad para fines publicos solamete in cualquier
tiempo despues de cincuenta anos desde el 13 le Julio le 1911, precio de la misma
propiedad, mas el valor que entonces tengan las mejoras."
For the remainder of the Luneta Extension, that is, after segregating therefrom the portion
sold to the Manila Lodge No. 761, PBOE, a new Certificate of Title No. 2196 3 was issued on
July 17, 1911 to the City of Manila.
Manila Lodge No. 761, BPOE, subsequently sold the said 5,543.07 square meters to the Elks
Club, Inc., to which was issued TCT No. 67488. 4 The registered owner, "The Elks Club, Inc.,"
was later changed by court order to "Manila Lodge No. 761, Benevolent and Protective Order
of Elks, Inc."
In January 1963 the BPOE. petitioned the Court of First Instance of Manila, Branch IV, for the
cancellation of the right of the City of Manila to repurchase the property This petition was
granted on February 15, 1963.

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On November 19, 1963 the BPOE sold for the sum of P4,700,000 the land together with all
the improvements thereon to the Tarlac Development Corporation (TDC, for short) which
paid P1,700.000 as down payment and mortgaged to the vendor the same realty to secure
the payment of the balance to be paid in quarterly installments.5 At the time of the sale,,
there was no annotation of any subsisting lien on the title to the property. On December 12,
1963 TCT No. 73444 was issued to TDC over the subject land still described as "UNA PARCELA
DE TERRENO, que es parte de la Luneta Extension, situada en el Distrito de Ermita.
In June 1964 the City of Manila filed with the Court of First Instance of Manila a petition for
the reannotation of its right to repurchase; the court, after haering, issued an order, dated
November 19, 1964, directing the Register of Deeds of the City of Manila to reannotate in
toto the entry regarind the right of the City of Manila to repurchase the property after fifty
years. From this order TDC and BPOE appealed to this Court which on July 31, 1968 affirmed
in G.R. Nos. L-24557 and L-24469 the trial court's order of reannotation, but reserved to TDC
the right to bring another action for the clarification of its rights.
As a consequence of such reservation, TDC filed on April 28, 1971 against the City of Manila
and the Manila Lodge No. 761, BPOE, a complaint, docketed as Civil Case No. 83009 of the
Court of First Instance of Manila, containing three causes of action and praying -
a) On the first cause of action, that the plaintiff TDC be declared to have purchased the
parcel of land now in question with the buildings and improvements thereon from the
defendant BPOE for value and in good faith, and accordingly ordering the cancellation of
Entry No. 4608/T-1635 on Transfer Certificate of Title No. 73444 in the name of the Plaintiff;
b) On the second cause of action, ordering the defendant City of Manila to pay the plaintiff
TDC damages in the sum of note less than one hundred thousand pesos (P100,000.00);
c) On the third cause of action, reserving to the plaintiff TDC the right to recover from the
defendant BPOE the amounts mentioned in par. XVI of the complaint in accordance with Art.
1555 of the Civil Code, in the remote event that the final judgment in this case should be that
the parcel of land now in question is a public park; and
d) For costs, and for such other and further relief as the Court may deem just and equitable
The Trial Court denied the petition. The petitioner appealed to the Court of Appeals but
affirmed the decision of the lower court.

ISSUE:
Whether the sale of the subject property executed by the City of Manila to the Manila Lodge
No. 761, BPOE, was void and inexistent for lack of subject matter.
RULING:
Yes. The sale of the subject property executed by the City of Manila to the Manila Lodge No.
761, BPOE, was void and inexistent for lack of subject matter. It suffered from an incurable
defect that could not be ratified either by lapse of time or by express ratification. The Manila
Lodge No. 761 therefore acquired no right by virtue of the said sale. Hence to consider now

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the contract inexistent as it always has seen, cannot be, as claimed by the Manila Lodge No.
761, an impairment of the obligations of contracts, for there was it, contemplation of law, no
contract at all.
The inexistence of said sale can be set up against anyone who asserts a right arising from it,
not only against the first vendee, the Manila Lodge No. 761, BPOE, but also against all its
successors, including the TDC which are not protected the doctrine of bona fide ii purchaser
without notice, being claimed by the TDC does not apply where there is a total absence of
title in the vendor, and the good faith of the purchaser TDC cannot create title where none
exists.
PRINCIPLE:
It is a cardinal rule of statutory construction that courts must give effect to the general
legislative intent that can be discovered from or is unraveled by the four corners of the
statute, 31 and in order to discover said intent, the whole statute, and not only a particular
provision thereof, should be considered.32 It is, therefore, necessary to analyze all the
provisions of Act No. 1360, as amended, in order to unravel the legislative intent.

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Item II. Essay Questions
1. The distinction between the strict and liberal constructions is that the former one should
be interpreted to the letter and the spirit should not be considered beyond the statute. On
the other hand, the latter one should be lenient and be interpreted liberally with intention to
advance the purpose or object of the statute.
To illustrate, in the case of Centeno v. Pornillos, G.R. No. 113092. September 1, 1994, the
Court cited that the interpretation of a penal statute, the tendency is to subject it to careful
scrutiny and to construe it with such strictness as to safeguard the rights of the accused. If
the statute is ambiguous and admits of two reasonable but contradictory constructions, that
which operates in favor of a party accused under its provisions is to be preferred. The
principle is that acts in and of themselves innocent and lawful cannot be held to be criminal
unless there is a clear and unequivocal expression of the legislative intent to make them
such. Whatever is not plainly within the provisions of a penal statute should be regarded as
without its intendment. The purpose of strict construction is not to enable a guilty person to
escape punishment through a technicality but to provide a precise definition of forbidden
acts. The word "charitable" is a matter of description rather than of precise definition, and
each case involving a determination of that which is charitable must be decided on its own
particular facts and circumstances. The law does not operate in vacuo nor should its
applicability be determined by circumstances in the abstract. Furthermore, in the provisions
of the Constitution and the statutes mentioned above, the enumerations therein given which
include the words "charitable" and "religious" make use of the disjunctive "or." In its
elementary sense, "or" as used in a statute is a disjunctive article in indicating an alternative.
It often connects a series of words or propositions indicating a choice of either. When "or" is
used, the various members of the enumeration are to be taken separately. Accordingly,
"charitable" and "religious," which are integral parts of an enumeration using the disjunctive
"or" should be given different, distinct, and disparate meanings.
There are cases wherein claims for exemption from tax for "religious purposes" have been
liberally construed as covered in the law granting tax exemptions for "charitable purposes."
Thus, the term "charitable purposes," within the meaning of a statute providing that the
succession of any property passing to or for the use of any institution for purposes only of
public charity shall not be subject to succession tax, is deemed to include religious purposes.

2. Penal laws are to be construed strictly against the state and liberally in favor of the
accused. The leniency rule, also known as the strict interpretation rule, is a principle of
criminal written interpretation that requires the court to apply any unclear or ambiguous law
in the most beneficial way for the defendant.
In the case of People v. Madrigal, G.R. No. L-2873, February 28, 1950, the Court cited that
the criminal and penal statutes must be strictly construed, that is, they cannot be enlarged or
extended by intendment, implication, or by any equitable considerations. In other words, the
language cannot be enlarged beyond the ordinary meaning of its terms in order to carry into
effect the general purpose for which the statute was enacted. Only those persons, offenses,
and penalties, clearly included, beyond any reasonable doubt, will be considered within the

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statute's operation. They must come clearly within both the spirit and the letter of the
statute, and where there is any reasonable doubt, it must be resolved in favor of the person
accused of violating the statute; that is, all questions in doubt will be resolved in favor of
those from whom the penalty is sought."
Hence, they should not be forced to build new crimes, expand the field of crime, or multiply
criminal offenses. Consequently, there is a tendency in the interpretation of criminal law to
subject it to scrutiny and to interpret it with such rigor as to guarantee the rights of the
accused. If a statute is ambiguous and permits two reasonable but conflicting constructs,
preference should be given to one that acts in favor of the accused in accordance with its
provisions. The principle is that actions in and of themselves innocent and lawful cannot be
considered criminal unless there is a clear and unambiguous expression of the legislative
intent to make them so. Anything that does not directly comply with the provisions of the
criminal law should be considered as having no intention of it. The purpose of strict
interpretation is not to allow the perpetrator to escape punishment by formality, but to
provide a precise definition of the prohibited conduct.
This interpretation does not run counter to the general rule that penal laws are to be strictly
construed, for this rule has an exception, namely, that it is not to be permitted to thwart the
clear and manifest intention of the legislator. Sutherland, in his work entitled "Statutes and
Statutory Construction," vol. II, page 985, paragraph 530, states the following:
In State vs. Small, the court, referring to the rule of strict construction of penal statutes, says:
"By this rule nothing more is meant than that penal statutes shall not, by what may be
thought their spirit and equity, be extended to offenses other than those which are
specifically and clearly described and provided for. The reason of the rule is that the law will
not allow of constructive offenses or arbitrary punishments. This rule of strict construction
does not exclude the application of common sense to the terms made use of in the act. Even
a penal statute should not be so construed as to work a public mischief, unless required by
words of explicit and unequivocal import. Effect must be given to the intent of the legislature
clearly apparent upon the face of the statute, although such construction seems contrary to
the exact letter of the statute.

3. Social legislation is a broad term and may include not only laws that give social security
protection, but also those that help the worker secure housing and basic necessities. It is the
policy of the Philippines which is to establish, develop, promote and improve sound and
feasible tax-free social security services that meet the needs of the entire Filipino people,
which will promote social justice and provide members and members with meaningful
protection and their beneficiaries.
In the case of Debaudin v. SSS, G.R. No. 148308, September 21, 2007, the Court cited that a
social legislation must be liberally construed in favor of the ordinary working person. While
the sympathy of the law on social security is toward the employees or their beneficiaries, it is
imperative to remember that such compassion must be balanced by the equally vital interest
of denying undeserving claims for compensation benefits.
The Comprehensive Agrarian Reform law could also be considered a social legislation.

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Focusing on the welfare of landless farmers and farmers, it is a national policy to establish
economic-scale farm owners and growers as the basis of Philippine agriculture. A land reform
program for this purpose, and based on the right of landless farmers and farmers to own the
land they cultivate, or to receive a fair share of the outcome of their labor. The program
essentially seeks to achieve this through the redistribution of farmland, subject to payment
only for the compensation of the disposed landowner (Section 2). Agricultural land
allocations shall be made to ideal family-sized farms as determined by the Presidential Land
Reform Council.
All land transferred to or suitable for agriculture, whether in the public or private sector, and
whether by individuals or companies—especially multinational corporations—are eligible for
redistribution through the program (Sections 4 and 8) . However, the landowner can reserve
the plot, the size of which may vary according to the standards set by PARC, but under no
circumstances should it exceed 5 hectares. Provide additional allowances for the children of
landowners. The disposal of private land by the landowner in violation of the above
restrictions is automatically invalidated (Article 6). A timetable is provided for the phased
implementation of all eligible agricultural land plans within a ten-year time frame.
The implementation will be carried out in three stages, according to the given priority
(Sections 5, 7 and 8) based on the type, size and nature of the land ownership status.
However, the commercial agricultural business plan was not included in the acquisition and
distribution plan until ten years after the Act entered into force (Article 11). For designated
types of land (Article 10), some exemptions and exclusion clauses within the scope of the
regulations are provided, and special guarantees are included to protect the interests of
indigenous cultural communities (Article 9). For the purpose of the land acquisition and
distribution plan, all land owners and all tenants, tenants and farm workers must register
with the government within a prescribed period (Article 14).
Land can be requisitioned for distribution, but fair compensation must be provided to the
land owner. The amount of compensation is determined through negotiation between the
government and the landowner, otherwise the court will resolve it through litigation (Article
16). A broad standard for determining what is justified compensation (Article 17).
Compensation can be paid in cash, stocks, tax credits or Philippine land bonds (Article 18).
Landless farmers—that is, farmers who own less than three hectares of agricultural land
(Article 25(2))—are eligible to allocate land according to the priority of a given farmer
category.
With the support of the Department of Agrarian Reform (sects. 35-38), support services will
be provided to the beneficiaries and landowners of the plan in areas such as irrigation and
infrastructure development, credit, marketing, research and promotion (Articles 35-38). The
Presidential Land Reform Commission was established to guide and guide the
implementation of the land plan.
Each province has established a Provincial Land Reform Commission to coordinate and
supervise the implementation of the plan. A land reform committee will also be established
at the Barangay government level to generally assist in the implementation of the plan and
mediate land disputes (Articles 41-49).

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The Department of Agrarian Reform is to have original jurisdiction over all disputes arising
under the Land Reform Program, and the Land Reform Department's decisions may be
considered by the Court of Appeals. In addition, the Special Agricultural Court, appointed by
the Supreme Court at the state level, is capable of hearing all cases relating solely to
compensation for landowners and prosecuting criminal offenses.

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