Caltex v. Palomar G.R. No.

L-19650 (1966)
Topic. Definition of Statutory Construction
Facts:
Caltex launched the "Caltex Hooded Pump Contest," in which contestants guessed the number of
liters contained in a covered pump. Participants do not need to purchase any Caltex products to
participate; instead, they must request entry forms from their local Caltex station. Winners would
be chosen at three levels: dealer, regional, and national. At the first level, whoever has the closest
determinations of the hooded pump contents wins, along with the other two runners-up, who
each receive a prize. The first prize in the Dealer Contest advances to the Regional level, and the
same mechanics as the first, second, and third prizes apply. The Regional Contest winner
advances to the National Contest.
Caltex requested that some relevant provisions in the Postal Law be waived in anticipation of the
scheme's impending mass use of mail. The Postal Law defines non-mailable items, authorizes the
issuance of fraud orders, and specifies the consequences of violating the law. Non-mailable items
include advertisements for lotteries, gift enterprises, and other similar schemes. In response to
Caltex's request, Postmaster Palomar denied Caltex's request, stating that its scheme falls under
lottery advertising, which is non-mailable matter. Caltex requested reconsideration; Postmaster
reiterated his stance, adding that if the scheme is carried out, a fraud order will be issued. Caltex
sought court intervention. And the trial court agreed with them. The Postmaster filed an appeal.
Issue:
Is the "Caltex Hooded Pump Contest" a violation of postal law?
Ratio:
The Court determined that the petition states a sufficient cause of action for declaratory relief
because it meets the four requirements for invoking declaratory relief, which are available to any
person whose rights are affected by a statute to determine any question of construction or
validity. To the petitioner, the construction restricts or interferes with its freedom to expand its
business, whereas to the respondent, suppression of the petitioner's proposed contest is an
unavoidable duty because it is believed to violate the law he has sworn to uphold and enforce.
Similarly, it was determined that the promotional scheme does not violate the Postal Law
because it does not involve a lottery or gift enterprise, using the rules of Statutory Construction
in determining the meaning and intention of the authors in a case clouded with doubt as to its
application. Using the principle of "noscitur a sociis," the term under construction should be
understood by the words that come before and after it. Thus, based on the definitions of lottery
and gift enterprise, which both require a prize, a chance, and consideration, the promo contest
does not clearly violate the Postal Law due to a lack of consideration.
Doctrine:
The "art or process of discovering and expounding the meaning and intention of the authors of
the law with respect to its application to a given case, where that intention is rendered doubtful,
among other things, by the fact that the given case is not explicitly provided for in the law,"
according to the definition. It is applicable in this case because the ponencia examined the
definition of "lottery" to reach a conclusion. It specifically applied when the court investigated
the meaning of lottery: consideration, prize, and chance. This allowed for a decisive
interpretation of the word under consideration.

People v. Mapa G. R. No. L-22301 (1967)

Topic. When construction is necessary

Facts:
In an information dated 14 August 1962, Mario M. Mapa was charged with illegal possession of
a firearm and ammunition in violation of Section 878 of the Revised Administrative Code in
connection with Section 2692 of the Revised Administrative Code, as amended by CA 56 and
further amended by RA 4. The accused admits to having a firearm because he is a secret agent
for Batangas Governor Feliciano Leviste. On November 27, 1963, the lower court issued a
decision convicting the accused of the crime and sentenced him to one year and one day to two
years in prison. The appeal was elevated to the Supreme Court because it involved a legal
question.
Issue:
Can a governor's secret agent carry a gun without the necessary permits?
Ratio:
No, he cannot, because the law does not grant such immunity to secret agents. According to the
law, "it shall be unlawful for any person to. . . Unless otherwise specified, "possess any firearm,
detached parts of firearms, or ammunition therefor, or any instrument or implement used or
intended to be used in the manufacture of firearms, parts of firearms, or ammunition." To that
end, the law states that "firearms and ammunition regularly and lawfully issued to officers,
soldiers, sailors, or marines [of the Armed Forces of the Philippines], the Philippine
Constabulary, guards in the employment of the Bureau of Prisons, municipal police, provincial
governors, lieutenant governors, provincial treasurers, municipal treasurers, municipal mayors,
and guards of provincial prisoners and jails" are exempt "when such firearms are in po As a
result, Mapa's carrying of his gun without the required permits is illegal.
Doctrine:
There is no exception in the law for a secret agent. The relevant Statutory Construction in this
case is: "Construction and interpretation come only after it has been demonstrated that
application is impossible or inadequate without them." Given that the law is adequate, the court
does not need to argue about what the law meant. There is no need for construction or
interpretation.
Daoang v. Municipal Judge G.R. No. L-34568 (1988)

Topic. When construction is necessary

Facts:
Mr. and Mrs. Agonoy applied for the adoption of two children, Bonillia and Marcos. While the
petition was being heard in court, minors Daoang and their father filed an opposition claiming
that the Agonoys could not adopt because they had a daughter, the oppositor's mother. They
claim to be the Agonoy's grandchildren despite the fact that their mother is no longer alive. The
petitioners rely on Art. 335 of the Civil Code, which lists entities that cannot adopt, one of which
is "those who have legitimate, legitimated, acknowledged natural children, or children by legal
fiction.
Issue:
Can Agonoy spouses adopt?
Ratio:
Yes, they can adopt because the law does not prohibit them from adopting grandchildren. Again,
the law states that entities that cannot adopt are "those who have legitimate, legitimated,
acknowledged natural children, or children by legal fiction." Borillia and Marcos can be adopted
by the Agonoys, who have no living children. It is undeniable that the petitioners are the
Agonoys' grandchildren. Having a grandchild, however, does not preclude the Agonoys from
adopting children. As a result, the Agonoys have the right to adopt.
It should be noted, however, that the Spanish Civil Code, from which the Philippine Civil Code
was derived, barred people with legitimate/d descendants from adopting, which would have
favored the opposition. When it was incorporated into the Civil Code, the framers substituted
"children" for "descendants."
Doctrine:
The relevant law makes it clear that having grandchildren is not on the list of entities that cannot
adopt. What should be remembered for this case in terms of statutory construction is that "a
statute clear and unambiguous on its face need not be interpreted; stated otherwise, the rule is
that only statutes with an ambiguous or doubtful meaning may be the subject of statutory
construction."
Alonzo v. Intermediate Appellate Court G. R. No. 72873 (1987)

Topic. Characteristics of construction: Necessary when legislative intent cannot be ascertained

Facts:
Five siblings inherited land from their deceased parent’s pro indiviso*. Alonzos purchased
Sibling 1's share. A year later, Sibling 2 sold his share to Alonzos. In their newly purchased land,
the Alonzos constructed a house and a fence. Sibling 3 lived on inherited land next to the
Alonzos' home. Sibling 2 shared the house with her. Sibling 3 is acquainted with Alonzos
because their children attended the same school. Sibling 4 filed for redemption 13 years later, but
it was denied because he is an American citizen. Sibling 3 filed a redemption complaint a year
later.
The complaint was dismissed by the trial court because the 30-day period for filing after notice
of sale had expired. According to Art. 1623 of the Civil Code, "the right of legal pre-emption or
redemption shall not be exercised except within thirty days from the notice in writing by the
prospective vendor/s." Since 13 years have passed, the court presumes that the siblings were
informed at some point and that the prescription has expired. Despite the fact that no written
notice was served on the siblings, the court determined that the complainants had actual
knowledge due to their proximity.
Issue:
Did the lower court correctly interpret and apply the relevant law?
Ratio:
Yes, the lower court applied the law correctly because the facts demonstrate the likelihood of the
notice occurring at some point. The relevant law is Article 1623 of the Civil Code, which states
that "the right of legal pre-emption or redemption shall not be exercised except within thirty days
of the prospective vendor/s' notice in writing." (1) One of the issues here is whether the
complainants were given notice. Even if we grant that no written notice was provided, it is
impossible to conclude that no notice was provided at all. They live next door to one another. (2)
When did the notice first appear? The Court does not know, but it is presumed that it began and
ended in the 13th years.
The law specifically states that the prescription of the right of redemption should be 30 days after
notice. Given the 13-year lapse, the court assumes the prescription has also expired.
Doctrine:
The complainants would have won this case under the letter of the law. However, due to the
circumstances, the Court adhered to the spirit of the law and granted the Alonzos leeway.
"Because the spirit, not the letter, of a statute determines its construction, a statute must be read
in accordance with its spirit or intent." For what is in the spirit is in the letter, even if it is not in
the letter itself, and what is in the letter but not in the spirit is not in the statute. To put it another
way, something that is within the intent of the legislator is as much within the statute as if it were
within the letter; and something that is within the letter of the statute is not within the statute
unless it is within the intent of the legislators." -Agpalo
*It was divided pro indiviso, not legally or formally, but only equally among the heirs.

Endencia v. David G.R. Nos. L-6355-56 (1953)

Topic. Characteristics of construction: Judicial function

Facts:
Prior to this case, the Supreme Court issued a decision in Perfecto v. Meer on the same issue. In
Perfecto, the Supreme Court determined that a judge is not required to pay income taxes because
it violates Art. VIII Sec. 9 of the Constitution states that judges "shall receive
compensation...which shall not be diminished during their continuance in office." As a result of
this decision, Congress passed RA 590, which declares that no public officer salary is exempt
from income tax. Its reasoning was that taxing salary does not result in a decrease in
compensation. Despite the passage of RA 590, the lower court that heard the case first ruled in
favor of the judges who followed the constitutional provision.
Issue:
Is RA 590 Constitutional even after SC decision?
Ratio:
No, because the Supreme Court, which has the authority to interpret laws, has already ruled on
the matter. Consider the concept of separation of powers. The legislature is in charge of making
laws, the executive is in charge of enforcing laws, and the judiciary is in charge of interpreting
and applying laws. Congress' insistence that taxing their salaries does not imply a reduction in
compensation is an interpretation of the phrase "which shall not be diminished during their
continuance." In short, Congress acted outside of its authority. Only the judiciary has the
authority to do what Congress has just done: interpret. Because RA 590 is unconstitutional, the
judiciary's decision in Perfecto is upheld. Insofar as the current case resembles Perfecto, the
instant case should also be decided in favor of the judges.
Doctrine:
The judiciary has the authority to interpret laws. If the Senate has decided a case involving a
constitutional provision, it cannot pass legislation that contradicts that provision.
Nitafan v. Commissioner of Internal Revenue G.R. No. 78780 (1987)

Topic. Purpose of construction: determine legislative intent

Facts:
The salaries of the judges have been deducted for tax purposes. Petitioners filed the current
petition in order to stop the deduction. In their petition, they claim that the law prohibits them
from having their salaries reduced. To support this, they propose the following previous and
current formulations of the relevant law:
"[Judges] shall receive such compensation as may be fixed by law, which shall not be diminished
during their continuance in office," according to the 1935 Constitution.
"The salary of the Chief Justice and the Associate Justices of the Supreme Court, and of judges
of inferior courts, shall be fixed by law, and shall not be reduced during their continuance in
office," according to the 1973 Constitution, and "No salary or any form of emolument of any
public officer or employee, including constitutional officers, shall be exempt from payment of
income tax."
"The salary of the Chief Justice and the Associate Justices of the Supreme Court, as well as
judges of lower courts, shall be fixed by law," according to the 1987 Constitution. Their salary
shall not be reduced during their tenure in office."
Petitioners claim that the original concept of "non-dimunition" was intended by the framers of
the 1973 Constitution.
Issue:
Should the salaries of the petitioner judges be taxed?
Ratio:
Because the Constitutional Commission intends, their salaries should be subject to income tax.
According to the Concom transcript, Commissioner Rigos intended to delete the proposed
exemption grant to the judiciary in order to equalize the three branches. Aside from Rigos,
Commissioner Bernas joked that their salaries should be subject to general income taxation, just
like all taxpayers. According to Commissioner Aquino, the exemption gives judges special
treatment and violates the principles of tax uniformity and equal protection under the law. In
order to achieve intergovernmental equality, Commissioner Rigos proposed changing
"diminished" to "decreased." Commissioner Bernas agreed with "reduced," but with the caveat
that it is taxed.
This modification has an impact on previously decided cases such as Perfecto and Endencia. The
doctrines in the two cases are now ineffective because they contradict the new law.
Doctrine:
In this case, the relevant Statutory Construction rule is: "The primary task in constitutional
construction is to ascertain and then assure the realization of the purpose of the framers and of
the people in the adoption of the Constitution." In order to determine the proper understanding of
the judge's salary as the law intended, the court had to examine the framers' intent.
People v. Concepcion 44 Phil. 126 (1922)

Topic. Purpose of Construction: determine legislative intent

Facts:
President Concepcion of the Philippine National Bank issued a memo limiting the discretionary
power of the local manager in Aparri, Cagayan to grant loans and discount negotiable documents
to P5000 to P10000.
Manager requested authorization from Concepcion regarding a loan from Puno y Concepcion.
PNB President Concepcion authorized Puno y Concepcion to extend credit in the amount of
P300,000. Six demand notes were used as security. The notes and interest were paid in full. Puno
y Concepcion was made up of several people, including PNB President Concepcion's wife,
Rosario San Agustin.
Cagayan CFI discovered PNB Pres. Concepcion was found guilty of violating Section 35 of Act
No. 2747, which states that "the National Bank shall not, directly or indirectly, grant loans to any
of the bank's board of directors or agents of branch banks." Section 49 of the same act prescribes
penalties. These, however, were later repealed by Act. No. 2938 in January 1921, following a
CFI decision.
Issue:
(1) Was the credit extension a "loan"? –Yes
(2) Did it refer to a "loan" or a "discount"? -Loan
(3) Was it considered a "indirect loan"? -Yes
(4) Can he be convicted even though the relevant provisions have been repealed? -Yes
(5) Did it violate Section 35 of the Act? Is it 2747? –Yes
(6) Is his good faith sufficient to defend him? -No
Ratio:
(1) Credit concession necessitates the granting of a loan.
(2) Because interest was not deducted from the face of the notes but was paid when they became
due, and they were single-name paper rather than double-name paper.
(3) They are a husband and wife.
(4) "Where a legislative act that penalizes an offense is repealed, such repeal does not have the
effect of depriving courts of jurisdiction to try, convict, and sentence offenders charged with
violations of the old law."
(5) The defense claims that 35 refers to a bank. 49 refers to a punishment on a person rather than
a bank. As a result, they argue that there is no penalty for the individual. This is incorrect. If a
corporation is prohibited from performing an act, so are its directors.
Doctrine:
Ratio 3 contains the principles. The phrase "directly or indirectly" may be difficult to grasp.
Looking at the legislative intent, on the other hand, would clear things up. The Legislature
intended to prohibit temptation for bank directors by including this phrase. Personal interest and
duty sometimes clash, and the provision anticipated this. In this case, it is clear that Concepcion's
desire to see his wife succeed trumped his duty to PNB. As a result, he is "indirectly" involved.

Definitions:
Individual credit: an individual's ability to borrow money as a result of a lender's confidence or
trust that he will pay what he promises.
Loan: the delivery of a given sum of money by one party and receipt of that sum of money by the
other party, subject to an express or implied agreement to repay the sum loaned, with or without
interest.
Interest is deducted ahead of time; always on double-name paper.
Loan: Interest is charged at the end of a credit, usually on single-name paper.

Tanada v. Yulo G.R. No.43575 (1935)

Topic. Purpose of construction: Limitation on the power of courts to construe

Facts:
1911, December: Tanada is appointed by the Governor-General as a justice of the peace in
Alabat, Tayabas, with the approval of the Philippine Commission.
Act No. 3899, November 1931, providing 65 y.o. Judges' retirement age has been approved.
Jan. 1, 1933: date for resignation under Act No. 3899
Tanada was transferred to Perez, Tayabas in September 1934, but remained in the same position.
Tanada turned 65 in October of 1935.
1935: The DOJ, through a CFI Judge, ordered Tanada to resign from office.

Issue:
(1) Takes action. Is Tanada covered by No. 3899? -No
(2) Does the transfer imply a new position? -No
Ratio:
(1) Tanada was under the age of 65 at the time the Act was passed. The law states that judges
who are already 65 years old at the time Act No. 3899 goes into effect must resign. In this
case, Tanada was only 64 years old when the Act was passed. Although Tanada did reach
65 later, this is irrelevant because the law only applies to those who reached the specified
age at the time of approval and not afterward.
(2) The transfer does not constitute a new appointment because it lacks the elements of an
appointment. Appointments must include two components: appointment by the
Governor-General and approval by the Philippine Senate. The Governor-signature
General's is all that is required for the transfer. Tanada's transfer is not an appointment
because his second reassignment was not approved by the Philippine Senate.
Furthermore, by definition, a transfer is an expansion or change in jurisdiction based on
the original appointment. Because it is based on the original appointment, no new
appointment is required.
Doctrine:
Ratio 1 shows the relevant statutory doctrine in this case. The defense claims that the relevant
provision is "defective and fails to convey the legislative intent." It was later revealed that the
defense was actually seeking the insertion of a phrase in the provision that would explicitly
disqualify Tanada from office. To address this argument, the court distinguishes between liberal
construction, which the court is permitted to do, and judicial legislation, which is outside the
scope of the court's jurisdiction. Through legislative intent, liberal construction allows courts to
determine the true meaning of a provision. Meanwhile, judicial legislation occurs when a court
adds certain elements/words to an omitted provision. In short, the defense sought judicial
legislation, which courts are not permitted to do.

Floresca v. Philex G.R. No. L-30642 (1985)

Topic. Purpose of Construction: Limitation on the power of courts to construe

Facts:
Philex is accused of failing to address safety concerns at the mining site prior to the accident. A
large amount of water accumulated in an open pit area, causing pressure in the working shafts
below. As a result, the area in question collapsed. Five of the 48 people escaped, and 22 were
rescued within a week. However, 21 people were left to die as a result of Philex's order to halt
the rescue mission.
The 21's heirs filed a civil complaint in CFI. Philex filed a motion to dismiss, claiming that the
accident is covered by the Workers' Compensation Act (WCA) and thus outside of the
jurisdiction of the CFI. The WCA states that (1) such work-related deaths fall under the
jurisdiction of the Workmen's Compensation Commission (WCC), and (2) if the employer is
negligent, the employer must pay the compensation plus 50% of the same compensation.
The petition was filed by the deceased's heirs.
Issue:
(1) Is the CFI competent?
(2) Can the petitioners only use WCA action, or can they choose between WCA action and civil
damage in regular court, or can they use both WCA and civil damage? –Select one, but not both.
Ratio:
To address the two issues, (2) should come first (1). (2) Petitioners must generally choose
between a WCA action and a civil suit. This is what Section 5 of the WCA provides, and it has
been applied in a number of court decisions. However, given the unusual nature of the cases, the
court decided to give the petitioners some leeway. The petitioners have already been
compensated under the WCA. They later discovered the true cause of the accident, which was
Philex's negligence. They then filed a civil lawsuit. The court reasoned that if the petitioners had
known about the case much sooner, they would have filed a civil suit instead. The court stated
that the petitioners' first recourse to WCA action was based on ignorance or a mistake of fact.
Petitioners were unable to choose between a WCA and a civil suit because they were not
informed of the true cause. As a result, an exception to Section 5 of the WCA is created. As a
result, the case was remanded to the lower court for proper judgment. (1) CFI now has
jurisdiction as a result of the court's exception to the case.
Doctrine:
Limitation on the power of courts to construe can be found in the court's discussion of the second
issue. According to the two dissenting opinions, a careful reading of Section 5 of the WCA
demonstrates that when a complainant has already received compensation through the WCA, his
or her right to sue in civil or other courts is understood to have been extinguished. Following the
passage of the WCA, the legislature had numerous opportunities to amend relevant provisions
but did not do so. According to the dissent, this demonstrates the legislative's continued intent to
retain the exclusivity provided therein. In the majority opinion's decision to allow petitioners to
file case despite receiving WCA compensation, the dissent contends that the court has legislated,
i.e. it has exercised a power beyond its capacities.
The majority opinion responds that it has not legislated. What it did was simply put the
Constitution and relevant statutes into effect. Secs. Art. 6, 7, and 9 II of the 1973 Constitution
ensures social justice, establishes adequate employment services, and protects labor. With these
provisions, the current court only gave effect to the petitioners' rights. There was no legislation
because the principles were already present and only needed to be applied.