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STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
Departure from literal interpretation the Third Party Complaint reasoning
that the said Complaint is not
Principle: Verba intentioni, non e contra, debent allowed under the Interim Rules of
inservire Procedure for Inter-Corporate
Words ought to be more subservient to the intent Controversies
than the intent to the words  Relevantly, the Interim Rules neither
state that the Third Party Complaint
The intention of the legislature and its purpose or
is one of the prohibited pleadings nor
object control the literal interpretation of
is it one of the allowed pleadings.
particular language of a statute, and a language
capable of more than one meaning is to be taken Issue:
in such sense as to harmonize with the intention
and object of the enactment.  Is the CA correct?
Held:
LITERAL IMPORT MUST YIELD TO INTENT
 No. While the Third Party Complaint
SY TIONG SHIOU v. SY CHIM and FELICIDAD
is not stated as one of the prohibited
CHAN SY, G.R. No. 174168, March 30, 2009
nor allowed pleadings, the conflict
Facts: may be resolved by following the
well-entrenched rule in statutory
 The corporation, of which both
construction that every part of the
petitioners and respondents are
statute must be considered with the
officers, filed an Amended Complaint
other parts, and kept subservient to
for Accounting and Damages against
the general intent of the whole
the Respondent Spouses.
enactment.
 The Respondent Spouses, after
 Indeed, the spirit and intent of the
having filed their Answer, also filed a
statute as may be found from the
Motion for Leave to File a Third Party
Interim Rules itself provides that the
Complaint, praying that the attached
Rules shall be liberally construed in
Third Party Complaint be admitted
order to promote their objective of
against herein Petitioners. The trial
securing a just, speedy, summary,
court granted such motion and
and inexpensive determination of
therefore admitted the third party
every action and proceeding.
complaint.
 Notably, jurisprudence has been
 Petitioners then questioned the
consistent in holding that the
admission of the Third Party
purpose of the third party complaint
Complaint before the CA through a
is to avoid a circuitry of action and
petition for certiorari. Ultimately, the
unnecessary of proliferation of law
CA reversed the trial court and ruled
suits. This, considering, the Third
that the trial court erred in admitting
Party Complaint shall be allowed.
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
CESSANTE RATIONE LEGIS, CESSAT ET IPSA LEX
Principle: Cessante ratione legis, cessat et ipsa lex
When the reason of the law ceases, the law itself
ceases.
The reason which induced the legislature to enact
a law is the heart of the law. For this reason, the
reason of the law plays a decisive role in its
construction. Consequently, its cessation or
nullification renders the law inoperative.
B/GEN. JOSE COMENDADOR v. GEN. RENATO S.
DE VILLA, G.R. No. 93177, August 2, 1991
Facts:
 Petitioners in GR No. 96948 are
facing prosecution for their alleged
participation in the failed coup d’ etat
which took place on December 1 to 9,
1990. The cases filed against them
were referred to General Courts of
Martial No. 14 for hearing.
 At the hearing, said Petitioners
manifested that they are exercising
their right to peremptory challenge
under Art. 18 of the Commonwealth
Act No. 48 or the Articles of War. The
GCM No. 14, however, ruled that
peremptory challenges had been
discontinued under PD No. 39
 Relevantly, PD 39, which govern the
procedure in Military Tribunals and
which also provides that no
peremptory challenges shall be
allowed, was issued subsequent to
the creation of the Military Tribunals
through General Order No. 8.
However, ultimately, General Order
No. 8 was revoked and the military
tribunals created pursuant thereto
were dissolved when then President
Marcos issued Proclamation No.
2045 which terminated the state of
martial law.
Issue:
 Is the GCM correct in ruling that the
right to peremptory challenge had
been discontinued under PD 39?
Held:
 No. It is a basic canon in statutory
construction that when the reason of
the law ceases, the law itself ceases.
 Thus, the withdrawal of the
peremptory challenge in PD 39
became ineffective when the
apparatus of martial law (the military
tribunals where before such tribunals
the right was discontinued) was
dismantled with the issuance of
Proclamation No. 2045.
 As a result, the old rule embodied in
Art. 18 of Com. Act No. 48 or the
Articles of War was automatically
revived. Under such Article, the right
to peremptory challenge is allowed.
Therefore, the GCM is wrong in ruling
that the said right is discontinued.
SUPPLYING LEGISLATIVE OMISSION
Principle: Where a literal import of the language
of a statute shows that words have been omitted
that should have been in the statute in order to
carry out its intent and spirit, clearly
ascertainable from the context, the court may
supply
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
supply the omission to make the statute conform
to the obvious intent of the legislature or to
prevent the act from being absurd.
GOVERNOR RODOLFO C. FARINAS v.
MAYOR ANGELO M. BARBA, G.R. No.
116763, April 19, 1996
Facts:
 Carlo Domingo, a member of the
Sangguniang Bayan ng San Nicolas,
Ilocos Norte, resigned after going
without leave to the United States.
 There were, in this case, two
significant recommendations made
to fill the vacancy in the Sangguniang
Bayan: (1) recommendation by the
Sangguniang Bayan ng San Nicolas of
Edward Palafox as member thereof
to Respondent Mayor Barba and (2)
recommendation by the
Sangguniang Panlalawigan of Al
Nacino and Carlito Domingo to
Petitioner Governor Farinas.
 Ultimately, Governor Farinas
appointed Al Nacino and Mayor
Barba, on the other hand, appointed
Edward Palafox.
 Both appointments are allegedly
made in pursuant to the provisions of
Section 45(c) of the LGC which
provides that “In case the permanent
vacancy is caused by a sangguniang
member who does not belong to any
political party, the local chief
executive shall, upon the
recommendation of the sangguniang
concerned, appoint a qualified
person to fill the vacancy”
Issue:
 Which of the two appointments was
correctly made?
Held:
 Neither.
 The “local chief executive” referred
to in Section 45(c), being the
appropriate provision in this case,
shall be understood in reference to
the provisions provided in Section
45(a) of the Code, whereby the
appointing authority shall be, in
particular, the Governor in case of
vacancy in the Sangguniang Bayan.
 Though, logically, Section 45(a)
pertains to vacancy created by a
member who belong to a political
party, except for those in the
Sangguniang Barangay whose
members are by law prohibited from
having any political party, the
drafters of Section 45 did not intend
to make the manner of filling the
vacancies in the Sanggunians,
created by members who do not
belong to any political party, be
different from the manner of filling
the vacancies in the Sanggunians,
created by those who belong to any
political party. Any difference in
procedure must be limited merely to
the fact that in the case of vacancies
caused by those who have a political
party, there is a political party which
can nominate while there is none in
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
the case of vacancies caused by one
who does not have a political party.
Accordingly, where there is no
political party which can nominate,
the Sanggunian, where the vacancy
occurred, shall be the appropriate
authority to make the appointment.
This is especially true by analogy to
vacancies created in the Sangguniang
Barangay whose members are by law
prohibited to have political
affiliations. Finally, implicit in the
provisions of Section 45(a) is the
policy to vest in the President, the
governor, and the mayor in
descending order to appoint or fill
vacancies, as follows:
o 1. President – sangguniang
panlalawigan and
sangguniang panlungsod of
highly urbanized and
independent component
cities
CONSTRUCTION TO AVOID ABSURDITY
o 2. Governor – sangguniang
panlungsod of component
cities and sangguniang bayan
o 3. Mayor – in the case of
sangguniang barangay, upon
recommendation of
sangguniang barangay
concerned
 With respect to the term
“sangguniang concerned” in Section
45(c), reference shall be had to
Section 45(a)(3). In the latter
provision, it is the sangguniang
barangay, where the vacancy
occurred, who shall make the
recommendation. Thus, in the same
manner, the sangguniang concerned
in Section 45(c) shall be understood,
in the sense that, since the vacancy
occurred in Sangguniang Bayan ng
San Nicolas, the sangguniang
concerned shall therefore be the
Sangguniang Bayan ng San Nicolas.
 In the case at bar, in the first
appointment concerned, Edward
Palafox was recommended by the
Sangguniang Bayan ng San Nicolas.
However, the appointment was
made by the Mayor.
 In the second, the appointment was
made by the Governor. However, the
recommendation came from the
Sangguniang Panlalawigan.
 Applying the foregoing decision of
the Court as to the meaning of
Section 45(c), since neither of the
two appointments were duly made,
neither shall be correct.
Principle: Interpretatio talis in ambiguis semper
fienda est ut evitetur inconveniens et absurdum
Where there is ambiguity, such interpretation as
will avoid inconvenience and absurdity is to be
adopted.
It is always presumed that the legislature
intended exceptions to its language which would
avoid absurd consequences.
Accordingly, the court has the power to supply or
omit the words from a statute in order to prevent
an absurd result. This is so for the Congress could
not have intended absurd interpretation of the
law.
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STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
PARAS v. COMELEC, G.R. No. 123169, 4
November 1996
Facts:
 Petitioner Danilo Paras is the incumbent
Punong Barangay of Barangay Pula of
Cabanatuan City who won the last
barangay election in 1994. A petition for
his recall was filed which Respondent
Comelec gave due course. Respondent
Comelec set the schedule for the signing
of the petition for recall which turned
out to be signed by 29.30% of the
registered voters—thus well beyond the
25% requirement—and therefore set
the schedule for the recall election.
Initially, the said recall election was set
in November 1995 but due to
Petitioner’s opposition it was ultimately
set on January 13, 1996.
 The basis for the recall election is Section
74 of the Local Government Code which
provides that: (a) any elective official
may be the subject of a recall election
only once during his term of office for
loss of confidence; (b) no recall shall take
place within one year from the date of
the official’s assumption to office or one
year immediately preceding a regular
local election.
 Petitioner cited the above provision in
order to stop the recall election
reasoning that the SK election, which
was held in one case as a regular local
election, is set to be held four months
away from the recall election.
Issue:
 Is the petitioner correct?
Held:
 No. In the interpretation of a statute, the
Court starts with the presumption that
the legislature intended to enact an
effective law. Too literal interpretation
of the law which leads to absurdity shall
not be countenanced.
 To the Court’s mind, to include the
aforesaid SK election to the “regular
local election” referred to in the
provision would be to unduly
circumscribe this novel provision of the
LGC on recall. If SK election would be so
considered, then no recall election can
ever be conducted rendering inutile the
provisions of Section 74 of the LGC.
 Also, the recall is potentially disruptive
of the normal working of the local
government because of the additional
expenses it entails, therefore, there is
the proscription against the conduct of
recall one year immediately preceding
the regular local election. This is so, for
in the said election, the electorate could
choose the concerned official’s
replacement which obviously would
have longer tenure than that who
succeeded in view of the recall election.
Necessarily, it would be more in keeping
with the intent of the recall provision of
the LGC to construe the “regular local
election” as that referring to the election
where the office held by the concerned
local official will be contested and filled
by the electorate.
 At any rate, the recall election shall not
be held inasmuch as the election for the
Punong Barangay is to be held six
months from date of this decision of the
Court—November 1996; May 1997
CONSTRUCTION IN FAVOR OF RIGHT AND
JUSTICE
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
Principle: In case of doubt in the interpretation
or application of law, it is presumed that the
lawmaking body intended right and justice to
prevail.
The Code Commission enacted this so that it may
tip the scales in favor of right and justice when
the law is doubtful or obscure. It will strengthen
the determination of the court to avoid an
injustice which may apparently be authorized by
some way of interpreting the law.
KAREN E. SALVACION v. CENTRAL BANK OF THE
PHILIPPINES, CHINA BANKING CORPORATION
and GREG BARTELLI y NORTHCOTT, G.R. No.
94723, August 21, 1997
Facts:
LAW DOES NOT REQUIRE THE IMPOSSIBLE
Principle: The law obliges no one to person an
impossibility.
In other words, a statute may not be so
construed as to require compliance with what it
prescribes cannot, at the time, be legally
accomplished.
In which case, substantial compliance with what
the law requires is sufficient.
PEDRO T. SANTOS, JR. v. PNOC, G.R. No.
170943, September 23, 2008
Facts:
 On December 23, 2002, a complaint for
a Sum of Money against herein
Petitioner was filed by herein
Respondent. The complaint is for the
purpose of collecting the amount of
around P698,000 from herein Petitioner
which was advanced to him by herein
Respondent when Petitioner was still a
member of its board of directors.
 Personal service of summons upon
petitioner failed because he could not be
located at his last known address despite
earnest efforts to do so. Thus, on
respondent’s motion, the trial court
allowed a service of summons by
publication.
 Despite the summons by publication and
also the attempt to serve upon him
summons through his last known
address, petition still failed to file his
Answer. Thus, on respondent’s motion,
the trial court granted in its September
11, 2003 Order the respondent’s ex
parte presentation and formal offer of
evidence. Said Order was sent by
registered mail to Petitioner’s last
known address.
 Subsequently, on October 28, 2003,
Petitioner then filed an Omnibus Motion
for Reconsideration and to Admit
Attached Answer. One of the claims of
the Petitioner is that he was denied of
due process as he was not notified of the
September 11, 2003 Order.
Issue:
 Is the claim of the Petitioner
meritorious?
Held:
 No.
 The law obliges no one to perform an
impossibility. Laws and rules must be
interpreted in a way that they are in
accordance with logic, common sense,
reason, and practicality.
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
 In this case, Petitioner’s whereabouts
and residence are not known. Indeed, it
took almost a year before Petitioner
came before the Court. So, what
happens if the residence and
whereabouts of the defending party are
not known or that if he cannot be
located? In such a case, there is
obviously no way notice can be sent to
him and that the notice requirement
cannot apply to him.
 Be that as it may, it may be stressed that
the Order—of which the petitioner
argues that he was not notified—was
still sent to his last known address.
NUMBER AND GENDER OF WORDS
Principle: When the context of the statute so
indicates, words in plural include the singular,
and vice versa.
Likewise, in construing a statute, the masculine,
but not the feminine, includes all genders unless
the context in which the word is used in the
statute indicates otherwise.
SANTILLON v. MIRANDA, G.R. No. 19281, June
30, 1965
Facts:
 Pedro Santillon died intestate leaving his
only son, Petitioner Claro Santillon and
his wife, Oppositor Perfecta Miranda. In
dividing the estate of Pedro Santillon,
Petitioner Claro argues that he should
get ¾ of the estate and then, ¼ shall
pertain to Oppositor Perfecta. On the
other hand, Oppositor Perfecta argues
that the division shall be ½ for her and ½
for Petitioner.
 Petitioner based his argument on Art.
892 which falls under the chapter on
Testamentary Succession. On the other
hand, Oppositor Perfecta rests her claim
on Art. 996 which fails under the chapter
on Legal or Intestate Succession.
 Relevantly, it was argued that Art. 996
cannot be made to apply in this case in
that the word “children” referred to
therein does not include the term
“child”. This is so, for the instant case
refers to a division of the estate in an
intestate proceeding wherein the
deceased is survived by his spouse and
his only child, not children.
Issue:
 Is the argument correct?
Held:
 No.
 It is a maxim of statutory construction
that words in plural include the singular.
 Thus, Art. 996—which, as worded,
provides “If a widow or widower and
legitimate children or descendants are
left, the surviving spouse has in the
succession the same share as that of
each of the children--could or should be
read as “if a widow or widower and
legitimate child are left, the surviving
spouse has in the succession the same
share as that of the child.”
MODULE 7: IMPLICATIONS
NECESSARY IMPLICATIONS
Principle: Ex necessitate legis or from the
necessity of the law.
What is implied in a statute is as much part as
that which is expressed.
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
Every statute is understood, by implication,
to contain all such provisions as may be
necessary to effectuate its object and
purpose, or to make effective rights, powers,
privileges or jurisdiction which it grants,
including all such collateral and subsidiary
consequences as may be fairly and logically
inferred from its terms.
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES (DENR) v. UNITED
PLANNERS CONSULTANTS, INC., G.R. No.
212081, February 23, 2015
Facts:
 Petitioner entered into an Agreement
for Consultancy Services with
respondent.
 For failure to pay its obligation under the
Consultancy Agreement despite
repeated demands, respondent
instituted a Complaint against petitioner
before the Regional Trial Court of
Quezon City, which complaint was later
referred to arbitration pursuant to the
arbitration clause in the Agreement.
 Ultimately, the Arbitral Tribunal
rendered its Award in favor of
Respondent; which Award was
confirmed by the RTC pursuant to
Special ADR Rules.
 Later, respondent moved for the
issuance of a writ of execution, which
the RTC later granted in an Order. By
reason of such Order, petitioner moved
to quash the writ of execution.
 However, the RTC, in its Order dated July
9, 2012 denied the said motion to quash,
which said Order was received by
petitioner on July 12, 2012. Dissatisfied
with the said Order, petitioner, on
September 10, 2012, filed a petition for
certiorari before the CA against the RTC
for confirming and ordering the
execution of the Arbitral Award.
 The CA dismissed the petition for
certiorari on the ground that the petition
was filed out of time.
 Rule 19.26 of the Special ADR Rules
provides that a special civil action for
certiorari may be filed to annul or set
aside the order of the RTC confirming a
domestic arbitral award; which petition
should be filed with the CA within 15
days from the notice of judgment, order
or resolution pursuant to Rule 19.28 of
the said Special ADR Rules.
 Petitioner, relevantly, argues that the
15-day period under said Special ADR
Rules shall not be applicable because the
Special ADR Rules did not provide
specifically for the procedure on
execution. What shall, therefore, be
applicable is the60-day period provided
under Rule 65 of the Rules of Court.
Issue:
Is the petitioner’s argument meritorious?
Held:
 No.
 Under the doctrine of necessary
implication, every statute is understood,
by implication, to contain all such
provisions as may be necessary to
effectuate its object and purpose, or to
make effective rights, powers, privileges
or jurisdiction which it grants, including
all such collateral and subsidiary
consequences as may be fairly and
logically inferred from its terms.
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
 In the case at bar, while it appears that
the Special ADR Rules remain silent on
the procedure for the execution of a
confirmed arbitral award, it is the
Court's considered view that the Rules'
procedural mechanisms cover not only
aspects of confirmation but necessarily
extend to a confirmed award's execution
in light of the said doctrine of necessary
implication. Execution is but a necessary
incident to the Court's confirmation of
an arbitral award. To construe it
otherwise would result in an absurd
situation whereby the confirming court
previously applying the Special ADR
Rules in its confirmation of the arbitral
award would later shift to the regular
Rules of Procedure come execution.
SUGBUANON RURAL BANK, INC. v. HON.
UNDERSECRETARY BIENVENIDO E. LAGUESMA,
G.R. No. 116194, February 2, 2000
Facts:
 Petitioner Sugbuanon Rural Bank, Inc.,
(SRBI, for brevity) is a duly-registered
banking institution. Private respondent
SRBI — Association of Professional,
Supervisory, Office, and Technical
Employees Union (APSOTEU) is a
legitimate labor organization affiliated
with the Trade Unions Congress of the
Philippines (TUCP), hereinafter referred
to as the Union.
 Later, the Union filed a petition for
certification election of the supervisory
employees of SRBI. Said petition was
however opposed by petitioner in its
motion to dismiss alleging that the
members of the Union were in fact
managerial or confidential employees.
 Relevantly, the applicable provision as
regards the disqualification of certain
employees from assisting, forming,
joining a union is Art. 245 of the Labor
Code. However, while the said Article
expressly mentions managerial
employees, it does not directly prohibit
confidential employees from engaging in
union activities.
Issue:
May confidential employees be considered as
not eligible under Art. 245 of the Labor Code?
Held:
 Yes.
 Under the doctrine of necessary
implication, the disqualification of
managerial employees are equally
applicable to confidential employees.
 The confidential-employee rule justifies
exclusion of confidential
employees because in the normal
course of their duties, they become
aware of management policies relating
to labor relations.
GRANT OF POWER INCLUDES INCIDENTAL
POWER
Principle: Where a general power is
conferred or duty enjoined, every particular
power necessary for the exercise of one or
the performance of the other is also
conferred.
Incidental powers are those which are
necessarily included in, and are therefore of
lesser degree than the power granted.
CARMELO F. LAZATIN v. HRET, G.R. No. 84297,
December 8, 1988
Facts:
 Per aspera ad astra • Ora et Labora • Ut In Omnibus Glorificetur Deus
STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante
 Petitioner and private respondent were
among the candidates for
Representative of the first district of
Pampanga during the elections of May
11, 1987.
 Later, Petitioner was proclaimed as
Congressman-elect. Private respondent
thus filed in the COMELEC a petition to
declare petitioner's proclamation
void ab initio.
 Later, the COMELEC declared
petitioner's proclamation void ab
initio. Petitioner then challenged the
COMELEC resolution before the
Supreme Court.
 In a decision promulgated on January 25,
1988, the Supreme Court set aside the
COMELEC's revocation of petitioner's
proclamation. Thus, on February 8,
1988, private respondent filed an
election protest in the House of
Representatives Electoral Tribunal.
 Relevantly, Petitioner moved to dismiss
the petition arguing that the election
protest was filed out of time pursuant to
Sec. 250 of the Omnibus Election Code.
The HRET, however, dismissed the said
motion of the petitioner ruling that the
election protest was filed on time
pursuant to Sec. 9 of the HRET Rules.
 Relevantly, Sec. 250 cannot be made
applicable in this case for the same
provision provides for election protests
concerning the Members of Batasang
Pambansa, regional, provincial, or city
official; the Batasang Pambansa, being
already abolished under the 1987
Constitution.
 On the other hand, while the
Constitution vests exclusive jurisdiction
over all contests relating to the election
of the Members of the Senate and the
House of Representatives in the
respective Electoral Tribunals, no
provision either in the Omnibus Election
Code nor in any executive orders
applicable to the May 11, 1987
Congressional elections can be found as
to the period within which to file
election protests in the Electoral
Tribunals.
Issue:
May the HRET promulgate rules as regards the
period within which to file an election protest
as it did as found under Section 9 of the HRET
Rules?
Held:
 Yes.
 It is a settled rule of construction that
where a general power is conferred or
duly enjoined, every particular power
necessary for the exercise of the one or
the performance of the other is also
conferred |||
 Thus, the power of the HRET, as the sole
judge of all contests relating to the
election of the Members of the House of
Representatives, to promulgate rules
and regulations relative to matters
within its jurisdiction, including the
period for filing election protests before
it, is beyond dispute. Its rule-making
power necessarily flows from the
general power granted it by
the Constitution.
CEMCO HOLDINGS, INC. v. NATIONAL LIFE
INSURANCE COMPANY OF THE PHILIPPINES,
INC., G.R. No. 171815, August 7, 2007
Facts:
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STATUTORY CONSTRUCTION
Notes compiled by Joanna Marie V. Carrera
Instructor: Atty. Darniel Bustamante

WHAT CANNOT BE DONE DIRECTLY CANNOT

BE DONE INDIRECTLY

Principle: Quando aliquid prohibetur ex

directo, prohibetur et per obliquum.

What the law prohibits cannot, in some other

way, be legally accomplished.

TAWANG MULTI-PURPOSE COOPERATIVE v. LA

TRINIDAD WATER DISTRICT, G.R. No. 166471,
March 22, 2011

Facts: