Philippine Veterans Bank Employees Union vs Judge Vega

G.R. No. 105364, 28 June 2001

FACTS:

On January 2, 1992, the Congress enacted R.A. 7169 providing for the rehabilitation of Philippine
Veterans Bank. It was published in the Official Gazette in February 24, 1992. Thereafter, petitioners
filed with the labor tribunals their residual claims for benefits and for reinstatement upon reopening
the bank.

In May 1992, the Central Bank issued a certificate of authority allowing the PVB to reopen despite
the late mandate for rehabilitation and reopening, Judge Vega continued with the liquidation
proceedings of the bank alleging further that RA 7169 became effective only on March 10, 1992 or 15
days after its publication in the Official Gazette on February 24, 1992.

ISSUE:

Whether or not RA 7169 became effective on January 2, 1992.

HELD:

Yes. RA 7169 expressly provided that it should take effect upon its approval. Aquino signed it into law
on January 2, 1992. Thereafter, said law became effective on said date. Its subsequent publication
was not necessary for its effectivity. RA 7169 is of internal nature and not have general application
thus it took effect on the date provided for and hence was rightfully invoked by the petitioners. The
Supreme Court upheld that while as a rule laws take effect after 15 days following completion of
their publication in the Official Gazette or in a newspaper of general circulation in the Philippines, the
legislature has the authority to provide for exceptions as indicated in the clause “unless otherwise
provided”.