Republic of the Philippines

UNIVERSITY OF NORTHERN PHILIPPINES

Tamag, Vigan City, Ilocos Sur

COLLEGE OF LAW

A COMPILATION OF CASE DIGESTS

IN STATUTORY CONSTRUCTION
 Bartolome v. Social Security System and Scanmar Maritime Services, Inc.
G.R. No. 192531, 12 November 2014.
Velasco, Jr., J.
Facts:
John Colcol was employed as an electrician by Scanmar Maritime Services, Inc.
As such, he was enrolled under the government's Employees' Compensation Program
(ECP). Unfortunately, on June 2, 2008, an accident occurred on board the vessel which
led to his untimely death the following day. John was, at the time of his death, childless
and unmarried. Thus, petitioner Bernardina P. Bartolome, John’s biological mother and,
allegedly, sole remaining beneficiary, filed a claim for death benefits under PD 626 with
the Social Security System (SSS) at San Fernando City, La Union. However, the SSS
La Union office, in a letter dated June 10, 2009 addressed to petitioner, denied the
claim because she was no longer the legal parent as John was adopted by one Cornelio
Colcol. The denial was appealed to the Employees’ Compensation Commission (ECC),
which affirmed the ruling of the SSS. In denying the claim, both the SSS La Union
branch and the ECC ruled against petitioner’s entitlement to the death benefits sought
after under PD 626 on the ground that petitioner can no longer be considered John’s
primary beneficiary. Hence, this petition.
Issue:
Are the biological parents of the covered, but legally adopted, employee
considered secondary beneficiaries and, thus, entitled, in appropriate cases, to receive
the benefits under the ECP?
Ruling:
Yes, the biological parents of the deceased are entitled to receive the benefits
under the Employee’s Compensation Program (ECP).
Article 167 (j) of the Labor Code provides the definition for beneficiaries, as
follows: “Beneficiaries means the dependent spouse until he remarries and dependent
children, who are the primary beneficiaries. In their absence, the dependent parents and
subject to the restrictions imposed on dependent children, the illegitimate children and
legitimate descendants who are the secondary beneficiaries; Provided, that the
dependent acknowledged natural child shall be considered as a primary beneficiary
when there are no other dependent children who are qualified and eligible for monthly
income benefit.”
Related to this is the maxim generalia verba sunt generaliter intelligenda or that
the law does not make a distinction that prevents us from making one. Thus, the term
"parents" in the phrase "dependent parents" in the Article 167 (j) of the Labor Code is
used and should be understood in its general sense and cannot be unduly limited to
"legitimate parents" as what the ECC did.
 Fernandez v. National Labor Relations Commission
G.R. No. 106090, 28 February 1994
Nocon, J.

Facts:
Petitioner was hired as a laborer at D.M. Consunji, Inc., a construction firm, on
November 5, 1974. He became a skilled welder and worked for private respondent until
March 23, 1986, when his employment was terminated on the ground that the project
petitioner had been assigned to was already completed and there was no more work for
him to do. However, petitioner brought his problem before the Labor Arbiter for illegal
dismissal. The Labor Arbiter decided in favor of petitioner and held that the termination
is illegal. Consequently, respondent is ordered to reinstate the complainant, who have
not yet reached the retirement age, to their former positions plus backwages of one (1)
year. However, private respondent argued that herein petitioner is only hired on a
project-to-project basis, depending on the availability of projects. Thus, the decision was
revised for lack of merit. In response, petitioner cited Article 280 of the Labor Code as
legal basis for the decision of the Labor Arbiter in his favor.
Art. 280. Regular and Casual Employment. — The provisions of written agreement to
the contrary notwithstanding and regardless of the oral agreement of the parties, an
employment shall be deemed to be regular where the employee has been engaged to
perform activities which are usually necessary or desirable in the usual business or
trade of the employer, except where the employment has been fixed for a specific
project or undertaking the completion or termination of which has been determined at
the time of the engagement of the employee or where the work or services to be
performed is seasonal in nature and the employment is for the duration of the season.
An employment shall be deemed to be casual if it is not covered by the preceding
paragraph: Provided, That, any employee who has rendered at least one year of service
whether such service is continuous or broken, shall be considered a regular employee
with respect to the activity in which he is employed, and his employment shall continue
while such actually exists.
He further argued that the proviso in Article 280 of the Labor Code supports his
claim that he should be regarded as a regular employee, hence, this petition.

Issue:
Is the petitioner entitled to him claims based on the proviso in Article 280 of the
Labor Code?

Ruling:
No, he is not entitled to him claims based on the proviso in Article 280 of the
Labor Code.
The proviso in the second paragraph of Article 280 of the Labor Code has
recently been explained in Mercado v. NLRC, where it was held that said proviso deems
as regular employees only those "casual" employees who have rendered at least one
year of service regardless of the fact that such service may be continuous or broken. It
is not applicable to "project" employees, who are specifically excepted therefrom.
 The general rule is that the office of a proviso is to qualify or modify only the
phrase immediately preceding it or restrain or limit the generality of the clause that it
immediately follows. Thus, it has been held that a proviso is to be construed with
reference to the immediately preceding part of the provision to which it is attached, and
not to the statute itself or to other sections thereof. The only exception to the rule is
where the clear legislative intent is to restrain or qualify not only the phrase immediately
preceding it (the proviso) but also earlier provisions of the statute or even the statute
itself as a whole.
 Carandang v. Santiago, et.al.
G.R. No. L-8238,25 May 1955
Labrador, J.

Facts:
Petitioner herein filed a complaint in the Court of First Instance of Manila to
recover from the defendant damages, both actual and moral, for the bodily injuries
received by him from the commission of the crime of frustrated homicide by said
accused Tomas Valenton Jr. After the defendants submitted their answer, they
presented a motion to suspend the trial of the civil case, pending the termination of the
criminal case against Tomas Valenton, Jr. in the Court of Appeals. The judge ruled that
the trial of the civil action must await the result of the criminal case on appeal. Petitioner
invoked Article 33 of the new Civil Code, which provides, “In cases of defamation, fraud
and physical injuries, a civil action for damages, entirely separate and distinct from the
criminal action, may be brought by the injured party. Such civil action shall proceed
independently of the criminal prosecution and shall require only a preponderance of
evidence.” Hence, this petition.

Issue:
What is the interpretation of the words “defamation”, “fraud”, and “physical
injuries” in Article 33 of the Civil Code?

Ruling:
Defamation and fraud are used in their ordinary sense because there are no
specific provisions in the Revised Penal Code using these terms as means of offenses
defined therein, so that these two terms defamation and fraud must have been used not
to impart to them any technical meaning in the laws of the Philippines, but in their
generic sense. The term "physical injuries" should be understood to mean bodily injury,
not the crime of physical injuries, because the terms used with the latter are general
terms.
The general rule is that words of a statutes must be taken in their “natural, plain
and ordinary signification in accordance with the common and approved usage of the
language” and that they must be given “their popularly accepted meaning”.
In this case, the use of a combination of the principles of construction in order to
determine legislative intent. The Court, applying the maxim noscitur asociis, concluded
that since the term “physical injuries” is associated with the terms, “defamation” and
“fraud”, which are not technical terms defined in the Revised Penal Code, the term
“physical injuries” should be understood in its generic sense.
 Manila Herald Publishing v. Ramos
G.R. No. L-42668, 18 January 1951
Tuason, J.
Facts:
Respondent filed a libel suit against the editors and reporters of Manila Herald,
securing a preliminary attachment in this case. Manila Herald then filed separate third-
party claims with the sheriff to quash the attachment, alleging that they were the owners
of the property attached, but was not granted because respondent was able to pay the
counter bond that was reduced as the respondent invoked Section 14 of Rule 59 of the
Rules of Court, which treats of the steps to be taken when property attached is claimed
by the other person than that defendant or his agent. Manila Herald then filed a joint suit
against the Sheriff to enjoin him from proceeding with the attachment of the properties.
This joint suit was dismissed by the lower court, ruling that Manila Herald should have
intervened in the libel suit originally filed by respondent, and prayed for the court for the
quashal of the preliminary attachment in that case. Hence, this petition.

Issue:
What is the meaning of the term “proper action” as used in Section 14 of Rule 59
of the Rules of Court?

Ruling:
Section 14 of Rule 59 of the Rules of Court, contains the proviso that "Nothing
herein contained shall prevent such third person from vindicating his claim to the
property by any proper action." In statutory construction, technical words are to be
understood in their technical sense. Hence, the Court held that the term “proper action”
has a technical meaning under the Rules of Court, as defined under Section 1, Rule 2
as “an ordinary suit in court of justice, by which one party prosecutes another for the
enforcement or protection of a right, or the prevention or redress of a wrong”, and under
Section 2, Rule 2 as “civil action may be commenced by filing a complaint with the
court.”
Moreover, the Court held that "action" has acquired a well-define, technical
meaning, and it is in this restricted sense that the word "action" is used in the above
rule. In employing the word "commencement" the rule clearly indicates an action which
originates an entire proceeding and puts in motion the instruments of the court calling
for summons, answer, etc, and not any intermediary step taken in the course of the
proceeding whether by the parties themselves or by a stranger. It was all the easier,
simpler, and the more natural to say intervention if that had been the purpose, since the
asserted right of the third-party claimant necessarily grows out of the pending suit, the
suit in which the order of attachment was issued.
 Geotina v. Court of Tax Appeals
G.R. No. L-33500, 30 August 1971
Teehankee, J.

Facts:
Petitioner is a domestic corporation duly organized and existing under and by
virtue of the laws of the Philippines. M/V "Mindanao Sea" arrived at the Port of Manila
carrying cartons fresh apples consigned to herein petitioner. After payment of the taxes
and duties on the portion of the shipment, the necessary transfer permits were issued
by the Collector of Customs of Manila. While this portion of the importation was being
unloaded from the carrying vessel and transported to the designated cold storage
house, the Collector of Customs, issued warrants of seizure and detention ordering the
seizure of a portion of the goods already unloaded and their detention for allegedly
having been imported in violation of Central Bank Circulars Nos. 289, 294 and 295, in
relation to Section 2530 (f) of the Tariff and Customs Code.
However, petitioner requested the Collector of Customs to have the goods
discharged from the vessel be delivered, but the Collector denied the request on the
ground that the importation of said goods is prohibited under the said Circulars of the
Central Bank and are, therefore, articles of prohibited importation under Section 102(k)
of the Tariff and Customs Code, which provides “"where articles are of prohibited
importation or subject to importation only upon conditions prescribed by law, it shall be
the duty of the Collector to exercise such jurisdiction in respect thereto as will prevent
importation or otherwise secure compliance with all legal requirements." Hence, this
petition.

Issue:
Are the fresh apples in question are "articles of prohibited importation” pursuant
to Section 1207, in relation to Section 102(k) of the Tariff and Customs Code?

Ruling:
No, the fresh apples in question are not "articles of prohibited importation”
pursuant to Section 1207, in relation to Section 102(k) of the Tariff and Customs Code.
The term “merchandise of prohibited exportation” used in the Tariff and Customs Code
is broad enough to embrace not only those already declared prohibited at the time of its
adoption but also goods, commodities, or articles that mat be the subject of the activities
undertaken in violation of subsequent laws. Taking into consideration that provisions of
the Central Bank circulars, although these are not statutes, have the force and effect of
the law that carrying out of transactions without complying to the requirements therein
are considered illegal.
 Microsoft Corporation v. Manansala, et.al.
G.R. No. 166391, 21 October 2015
Bersamin, J.

Facts:
This case involves the interpretation of Section 5 of P.D. No. 49, which provides
“Copyright shall consist in the exclusive right; (a) to print, reprint, publish, copy,
distribute, multiply, sell, and make photographs, photo-engravings, and pictorial
illustrations of the works”, whether a person can be held liable for copyright
infringement if he is engaged in selling and distribution of unauthorized Microsoft
computer programs, without evidence that the same person is also the one who printed
or copied the products for sale in his store.
Private respondent Manansala, without authority from petitioner, was engaged in
distributing and selling Microsoft computer software programs when a private
investigator accompanied by an agent from the National Bureau of Investigation (NBI)
was able to purchase six (6) CD-ROMs containing various computer programs
belonging to petitioner. As a result of the test-purchase, the agent from the NBI applied
for a search warrant to search the premises of the private respondent and yielded
several illegal copies of Microsoft programs. However, the CA dismissed the criminal
charges filed against the respondents on the ground that the term “and” as used under
Section 5 of P.D. No. 49 should be read as a conjunctive. Hence, this petition.

Issue:
Is the term “and” signify a conjunctive relationship as used under Section 5 of
P.D. No. 49?

Ruling:
No, the term “and” does not signify a conjunctive relationship as used under
Section 5 of P.D. No. 49 if such interpretation will be contrary to the clear legislative
intent. The conjunctive “and” should not be taken in its ordinary acceptation, but should
be construed like the disjunctive “or” if the literal interpretation of the law would pervert
to obscure the legislative intent.
The CA erred in its reading and interpretation of the abovementioned provision.
Under the rules on syntax, the conjunctive word "and" denotes a "joinder or union" of
words, phrases, or clause; it is different from the disjunctive word "or" that signals
disassociation or independence. However, a more important rule of statutory
construction dictates that laws should be construed in a manner that avoids absurdity or
unreasonableness.
 Marcelino v. Cruz, et.al.
G.R. No. L-42428, 11 July 1952
Escolin, J.

Facts:
Marcelino was charged with the crime of rape before CFI Rizal. Trial was
conducted and the same was concluded when the accused rested its case on August 4,
1975. Counsels for both parties moved for time within which to submit their respective
memoranda. The trial court granted the motion, and the parties were given 30 days to
submit, that is on September 4, 1975.
On November 28, 1975, Judge Cruz filed with the deputy clerk of court his
decision in said case for promulgation. Counsel for the accused raised the alleged loss
of jurisdiction of trial court for failure to decide the case within 90 days from submission
thereof for decision. Section 11(1) of Article X states that: “Upon the effectivity of this
Constitution, the maximum period within which a case or matter shall be decided or
resolved from the date of its submission, shall be eighteen months for the Supreme
court, and, unless reduced by the Supreme Court, twelve months for all inferior
collegiate courts, and three months for all other inferior courts.”
Petitioner argued that the three-month period prescribed by Section 11 of Article
X of the 1973 Constitution, being a constitutional directive, is mandatory in character
and that non-observance thereof results in the loss of jurisdiction of the court over the
unresolved case. Hence, this petition.

Issue:
Is the provision under Section 11 of Article X of the 1973 Constitution mandatory
in character?

Ruling:
The Court ruled that the word “shall” therein should be construed as directory
and not mandatory in character. The established rule is that "constitutional provisions
are to be construed as mandatory, unless by express provision or by necessary
implication, a different intention is manifest." "The difference between a mandatory and
a directory provision is often determined on grounds of expediency, the reason being
that less injury results to the general public by disregarding than by enforcing the letter
of the law."
Moreover, the phraseology of the provision in question indicates that it falls within
the exception rather than the general rule. Albermarle Oil & Gas Co. v. Morris, declares
that constitutional provisions are directory, and not mandatory, where they refer to
matters merely procedural.
 In Re: Guariña
G.R. No. 1179, 8 January 1913
Carson, J.
Facts:
Relying upon the provisions of Section 2 of Act No. 1597, Mario Guariña seeks
admission to the bar, without taking the prescribed examination, on the ground that the
holds the office of provincial fiscal for the Province of Batanes. It provides that: “Those
who have been duly licensed under the laws and orders of the Islands under the
sovereignty of Spain or of the United States and are in good and regular standing as
members of the bar of the Philippine Islands at the time of the adoption of this
Code...may be licensed to practice law in the courts of the Philippine Islands without an
examination, upon motion before the Supreme Court and establishing such fact to the
satisfaction of said court."
However, the records disclosed that on a former occasion, Guariña took, and
failed to pass the prescribed examination. The report of the examining board, dated
March 23, 1907, shows that he received an average of only 71% in the various
branches of legal learning upon which he was examined, thus falling four points short of
the required percentage of 75.

Issue:
Is the word “may” in Section 2 of Act No. 1597 shall be construed as mandatory
and imposing a duty, or merely a permissive discretion?

Ruling:
Without undue straining of the language used in the statute under consideration,
the word "may" may be construed as either mandatory or permissive in its effect. But to
construe it as mandatory would bring it in direct conflict with the Act of Congress, and
we conclude therefore, despite the contentions of the applicant as to the apparent
intention of the legislator, that it should be given its permissive and not its mandatory
effect, and that the true intention of the legislator was to leave it within the discretion of
the court to admit to the bar without examination the officials mentioned in the Act in any
case wherein the court is otherwise satisfied that they possess the necessary
qualifications.
 Sterling Selections Corp. v. Laguna Lake Development Authority
G.R. No. 171427, 30 March 2011
Nachura, J.

Facts:
Several complaints were filed against the petitioner for "creating loud unceasing
noise and emitting toxic fumes” coming from their manufacturing plant. Upon inspection,
a Notice of Violation and a Cease and Desist Order (CDO) were served on petitioner
after it was found that it was operating without an LLDA Clearance and Permit, as
required by Republic Act (R.A.) No. 4850. Petitioner is engaged in the fabrication of
sterling silver jewelry is claiming exemption from the requirement of securing a
Clearance Permit from Laguna Lake Development Authority on the ground that he is
engaged in a cottage industry based on the provision under Section 2(30) of LLDA
Resolution No. 41, Series of 1997, which provides that cottage industries, including
stuffed toys manufacturing, handicrafts, and rattan/furniture manufacturing are exempt
from the clearance requirement.
The CA held that, following the principle of ejusdem generis, the enumeration in
the foregoing provision must be taken to include businesses of the same kind, which
were, as averred by the LLDA, not as environmentally critical as those enumerated.
Thus, the CA declared that the LLDA did not contemplate the inclusion of the
manufacture of jewelry in the exemptions. The petitioner questioned the interpretation of
the CA, arguing that the above provision contains no restriction limiting the exemptions
to only certain kinds of cottage industries, and argued that the use of the word
“including” connotes a sense of “containing” or “comprising” and not a sense of
exclusivity or exclusion. Hence, this petition.

Issue:
Does the word “including” in the provision under Section 2(30) of LLDA
Resolution No. 41, Series of 1997 means a sense of “containing” or “comprising” and
not a sense of exclusivity or exclusion?

Ruling:
The Supreme Court ruled that the word “include” means “to take part in or
comprise as a part of the whole”. Further, it necessarily conveys the very idea of non-
exclusivity of the enumeration. The principle of expressio unius est exclusio alterius (the
explicit inclusion of certain things implies the exclusion of those not included) does not
apply where other circumstances indicate that the enumeration was not intended to be
exclusive, or where the enumeration is by way of example only. The maxim expressio
unius est exclusio alterius does not apply when words are mentioned by way of
example. Said legal maxim should be applied only as a means of discovering legislative
intent which is not otherwise manifest.
 Nevertheless, petitioner is not covered by the exemption provided for cottage
industries on the ground that the petitioner’s business exceeded the threshold on
maximum capital for cottage industries exempt from the clearance requirement.

McGee v. Republic
G.R. No. L-5387, 29 April 1954
Montemayor, J.

Facts:
Clyde E. McGee, an American citizen is married to Leonarda S. Crisostomo by
whom he has one child. The minors Maria and Amada, both surnamed Magpayo are
Leonarda’s children by her first husband Ernesto Magpayo who was killed by the
Japanese during the occupation. McGee filed a petition in the Court of First Instance of
Manila to adopt his two minor step-children Maria and Amada. At the hearing, the
Government filed its opposition to the petition on the ground that petitioner has a
legitimate child and consequently, under Article 335, paragraph 1, of the new Civil Code
which provides that those who have legitimate, legitimated, acknowledged natural
children, or natural children by legal fiction is disqualified to adopt.
However, the trial court overruled the opposition and granted the petition,
applying the provisions of Article 338 of the same Civil Code, particularly paragraph 3
thereof, which provides that a step-child, by the step-father or step-mother may be
adopted. Hence, this petition.

Issue:
Whether negative words and phrases in a statute are to be regarded as
mandatory while those in the affirmative are merely directory.

Ruling:
Yes. Under the rule of statutory construction, negative words and phrases are to
be regarded as mandatory while those in the affirmative are merely directory.
In the case at bar, Article 338 of the New Civil Code should be subordinated and
made subject to the provisions of Article 335 so as to limit the permission to adopt
granted in Article 338, to parents who have no children of their own, is that the terms of
Article 335 are phrased in a negative manner - the following cannot be adopted, while
the phraseology of Article 338 is only affirmative - the following may be adopted.
Prohibitive or negative words can rarely, if ever, be directory, or, as it has been
aptly stated, there is but one way to obey the command ’thou shalt not’, and that is to
completely refrain from doing the forbidden act. And this is so, even though the statute
provides no penalty for disobedience.
 Lokin v. COMELEC
G.R. Nos. 179431 to 32, 22 June 2010
Bersamin, J.

Facts:
The Citizen’s Battle Against Corruption (CIBAC), a duly registered party-list
organization, manifested their intent to participate in the May 14, 2004 synchronized
national and local elections. They submitted a list of five nominees from which its
representatives would be chosen should CIBAC obtain the number of qualifying votes.
However, prior to the elections, the list of nominees was amended: the nominations of
the petitioner Lokin, Sherwin Tugna and Emil Galang were withdrawn; Armi Jane Borje
was substituted; and Emmanuel Joel Villanueva and Chinchona Cruz-Gonzales were
retained.

Election results showed that CIBAC was entitled to a second seat and that Lokin,
as second nominee on the original list, to a proclamation, which was opposed by
Villanueva and Cruz-Gonzales. The COMELEC en banc proclaimed Cruz-Gonzales as
the official second nominee of CIBAC. Cruz-Gonzales took her oath of office as a Party-
List Representative of CIBAC. Petitioner then filed a petition assailing Section 13 of
Resolution No. 7804 alleging that it expanded Section 8 of R.A. No. 7941 by allowing
CIBAC to change its nominees.

Issue:
Is the enumeration of exceptions prohibiting changes or alterations in the order of
nominees of a partylist under Section 8 of R.A. No. 7941 exclusive?

Ruling:
Yes, the enumeration is exclusive, for necessarily, the general rule applies to all
cases not falling under the three exceptions under Section 8 of R.A. No. 7941.
When the statute itself enumerates the exceptions to the application of the
general rule, the exceptions are strictly but reasonably construed. The exceptions
extend only as far as their language fairly warrants, and all doubts should be resolved in
favor of the general provision rather than the exceptions. Where the general rule is
established by a statute with exceptions, none but the enacting authority can curtail the
former. Not even the courts may add to the latter by implication, and it is a rule that an
express exception excludes all others, although it is always proper in determining the
applicability of the rule to inquire whether, in a particular case, it accords with reason
and justice.
 The appropriate and natural office of the exception is to exempt something from
the scope of the general words of a statute, which is otherwise within the scope and
meaning of such general words. Consequently, the existence of an exception in a
statute clarifies the intent that the statute shall apply to all cases not excepted.
Exceptions are subject to the rule of strict construction; hence, any doubt will be
resolved in favor of the general provision and against the exception. Indeed, the liberal
construction of a statute will seem to require in many circumstances that the exception,
by which the operation of the statute is limited or abridged, should receive a restricted
construction.

National Marketing Corporation v. Tecson

G.R. No. L-29131, 27 August 1999
Concepcion, C.J.

Facts:
Miguel D. Tecson appealed to move to dismiss the previously judged Civil Case
No. 20520 because it was upon lack of jurisdiction over subject matter thereof and
prescription of action. The National Marketing Corporation, as successor to all the
properties, assets, rights, and chooses in action of the Price Stabilization Corporation,
as plaintiff in that case and judgment creditor therein, filed, with the same court, a
complaint against Mr. Tecson, for the revival of the judgment rendered in the previous
case. Acting upon the motion and plaintiff’s opposition thereto, said Court issued, on
February 14, 1966, an order reading: “Defendant Miguel Tecson seeks the dismissal of
the complaint on the ground of lack of jurisdiction and prescription. As for prescription,
plaintiffs admit the decision of this Court became final on December 21, 1955. This case
was filed exactly on December 21, 1965 — but more than ten years have passed a year
is a period of 365 days (Art. 13, CCP). Plaintiff forgot that 1960, 1964 were both leap
years so that when this present case was filed it was filed two days too late.”
The National Marketing Corporation appealed from such order to the Court of
Appeals, upon the ground that whether or not the present action for the revival of a
judgment is barred by the statute of limitations. Hence, this petition.

Issue:
Whether the computation of prescriptive period should be based on the legal
periods provided under Section 31 of the Revised Administrative Code of 1987 or Article
13 of the Civil Code.

Ruling:
Plaintiff-appellant insists that the same "is erroneous, because a year means a
calendar year (Statutory Construction, Interpretation of Laws, by Crawford, p. 383) and
since what is being computed here is the number of years, a calendar year should be
used as the basis of computation. The very conclusion thus reached by appellant shows
that its theory contravenes the explicit provision of Art. 13 of the Civil Code of the
Philippines, limiting the connotation of each "year" — as the term is used in our laws —
to 365 days. Meanwhile, Section 13 of the Revised Administrative Code, a month shall
be understood to refer to a calendar month. The latter shall prevail because it amended
the provisions of the Civil Code pertaining to the computation of legal periods.
 Government Service Insurance System v. Corrales
G.R. No. 166261, 27 June 2008
Austria-Martinez, J.

Facts:
Respondent filed with petitioner a claim under P.D. No. 626 for disability benefits
representing the cost of her hospitalization. Petitioner denied the claim on the ground
that respondent's disability was non-compensable, for it arose from an "ailment that is
not considered an occupational disease as contemplated under the aforementioned
law." However, the ECC ruled that the said ailment therefore is in no way caused by any
form of employment. It is a non-work connected ailment and neither causal relationship
nor increased risk can be established between appellant's work and this ailment. The
respondent appealed to the CA on the argument that CHD is a form of cardiovascular
disease which is considered as an occupational disease under item No. 18.
Cardiovascular diseases x x x" in the List of Occupational and Compensable Diseases
(Annex "A") attached to the Amended Rules on Employees' Compensation,
implementing P.D. No. 626.The CA ruled in favor the respondent, hence this petition.

Issue:
Does the category of occupational diseases listed as "18. Cardiovascular
diseases x x x" in Annex "A" include congenital forms of cardiovascular diseases such
as CHD?

Ruling:
Yes. The Court ruled that when a term is used in its plural sense, it is to be
interpreted to encompass any and all related meanings of the term.
Thus, "cardiovascular diseases" must mean all diseases of the cardiovascular
system, without qualification as to nature, origin, or type. The CA, therefore, did not err
when it held that respondent's CHD fell under the category of work-related diseases
listed as "18. Cardiovascular diseases" in Annex "A" of the Amended Rules on
Employees' Compensation.
It being settled that respondent's CHD is listed in Annex "A" as an occupational
disease, the next question is whether her ailment was acquired under any of the
conditions set forth in Annex "A" so as to be considered compensable.