1. Francisco v. HRET, G.R. No.

160261, November 10, 2003

FACTS

In 2003, Former President Estrada filed an impeachment complaint against Chief Justice Davide Jr., which was
dismissed by the House Committee on Justice for lacking substance. The Committee Report was not sent to the
House in plenary. Shortly after, a second impeachment complaint was filed, leading to legal challenges. The key
issue revolves around the interpretation of a constitutional provision stating that no impeachment proceedings can be
initiated against the same official within one year. The House argues that the one-year bar has not been violated
because the first complaint has not been officially initiated by the House as a collective body. The distinction is
made between filing a complaint and the formal initiation of impeachment proceedings by the House. The argument
suggests that until the House takes specific action on the first complaint, the one-year limitation does not apply.

ISSUES:

WON the second impeachment complaint barred under Section 3(5) of Art. XI of the Constitution.

RULING

YES. According to the Constitutional Commission's deliberations, asserts that the initiation of impeachment
proceedings stems from filing a complaint, not a one-third vote in a House resolution. It opposes accepting a second
verified complaint within a year of the first. The argument challenges the notion that only the House can initiate
impeachment proceedings, emphasizing a misunderstanding of terms. Reddendo singula singulis is cited to stress the
need to distinguish between "impeachment cases" and "proceedings." This principle is further applied to clarify that
the House's exclusive power to initiate cases involves bringing a legal dispute to the Senate, while the initiation of
the impeachment proceeding occurs distinctively during the trial stage.

The well-settled principles of constitutional construction: First, verba legis, that is, wherever possible, the words
used in the Constitution must be given their ordinary meaning except where technical terms are employed. Second,
where there is ambiguity, ratio legis est anima. The words of the Constitution should be interpreted in accordance
with the intent of its framers. The object is to ascertain the reason which induced the framers of the Constitution to
enact the particular provision and the purpose sought to be accomplished thereby, in order to construe the whole as
to make the words consonant to that reason and calculated to effect that purpose. It may also be safely assumed that
the people in ratifying the Constitution were guided mainly by the explanation offered by the framers. Finally, ut
magis valeat quam pereat. The Constitution is to be interpreted as a whole. Sections bearing on a particular subject
should be considered and interpreted together as to effectuate the whole purpose of the Constitution and one section
is not to be allowed to defeat another, if by any reasonable construction, the two can be made to stand together.

2. Tarlac Development Corporation v. CA, L-41012, September 30, 1976

DOCTRINE
There is also an ambiguity when a literal interpretation of the words would lead to unreasonable, unjust or absurd
consequences, or where a statute is in conflict with the Constitution, or where the statute would defeat the policy of
the legislation.

FACTS

The Philippine Commission enacted Act No. 1306 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 the city is authorized to set aside a tract of the reclaimed land for a
hotel site and to lease or to sell the same. Later, the City of Manila conveyed a portion of the reclaimed area to
Petitioner. Then Petitioner sold the land, together with all the improvements, to the Tarlac Development Corporation
(TDC).

ISSUE

Whether the subject property was patrimonial property of the City of Manila.

RULING

The petitions were denied for lack of merit. The court found it necessary to analyze all the provisions of Act No.
1360, as amended, in order to unravel the legislative intent. The grant made by Act No. 1360 of the reclaimed land
to the City of Manila is a grant of a “public” nature. Such grants have always been strictly construed against the
grantee because it is a gratuitous donation of public money or resources, which resulted in an unfair advantage to the
grantee. In the case at bar, the area reclaimed would be filled at the expense of the Insular Government and without
cost to the City of Manila. Hence, the letter of the statute should be narrowed to exclude matters which, if included,
would defeat the policy of legislation.

3. REGIDOR v. CHIONGBIAN (G.R. No. 85815, May 19, 1989

DOCTRINE

REGULATIONS ISSUED BY THE SECRETARY OF THE LOCAL GOVERNMENT CANNOT ALTER, AMEND
OR CONTRAVENE PROVISION OF THE LOCAL GOVERNMENT CODE

No rule or regulation issued by the Secretary of Local Government may alter, amend, or contravene a provision of
the Local Government Code. The implementing rules should conform, not clash, with the law that they implement,
for a regulation which operates to create a rule out of harmony with the statute is a nullity. A rule or regulation that
was issued to implement a law may not go beyond the terms and provision of the law.

FACTS

Petitioners, Eleno T. Regidor Jr. (City Mayor of Tangub City), Aniceto T. Siete (Vice-Mayor), Camilo B. Zapatos,
and Rodulfo Enriquez (members of the Sangguniang Panglunsod) were elected in the January 18, 1988 local
elections, proclaimed duly, and assumed office.

Respondents, William Chiongbian (Provincial Governor), Florencio Garcia (Vice-Governor), and members of the
Sangguniang Panlalawigan approved Resolution No. 340-88, recommending the suspension of petitioners for
unspecified misconduct.

On November 3, 1988, Resolution No. 340-88 was approved, recommending the suspension of petitioners. Pursuant
to this, Governor Chiongbian issued an Order of Preventive Suspension on November 24, 1988, suspending
petitioners for 60 days, effective November 25, 1988. The Governor appointed Robert O. Taclob, a member of his
political faction, as Officer-in-Charge of Tangub City.

Petitioners filed a petition for prohibition, arguing that the respondents acted without authority and contrary to the
law in issuing the Order of Preventive Suspension.

ISSUES

Whether the preventive suspension was in accordance with the provisions of the Local Government Code.

RULING

NO. The court ruled that the authority to impose preventive suspension on elected officials is clearly defined in the
Local Government Code. Section 63 of the Code specifies that the Minister of Local Government has the authority
to impose preventive suspension on provincial or city officials. Implementing rules and regulations must conform to
the law they aim to implement. The specific delineation of powers for preventive suspension under Section 63
should be adhered to, and any deviation from it is considered null and void. The court declared the notice of hearing,
subpoena, and order of preventive suspension issued by the respondents null and void. It annulled Resolution No.
340-88, the order of preventive suspension, and the appointment of the Officer-in-Charge.

No rule or regulation issued by the Secretary of Local Government may alter, amend, or contravene a provision of
the Local Government Code. The implementing rules should conform, not clash, with the law they implement. The
temporary restraining order issued earlier was made permanent.

In summary, the court emphasized the importance of adhering to the specific provisions of the Local Government
Code regarding the authority to impose preventive suspension on elected officials and emphasized that
implementing rules and regulations must not contravene the law they seek to implement.

4. Sumulong v COMELEC (GR No. 47903, November 29, 1940)

FACTS
The Commission on Elections, under the authority of section 5 of Commonwealth Act No. 657, issued a resolution
for the appointment of election inspectors proposed by political parties.

Pagkakaisa Ng Bayan, a political party, challenges the constitutionality of section 5, specifically the requirement
that a political party must have polled at least ten percent of the total votes cast in the preceding election to propose
the appointment of election inspectors.
Issues:

ISSUES

1. Whether section 5 of Commonwealth Act No. 657, which sets the criteria for political parties to propose the
appointment of election inspectors, is constitutional.

2. Whether the resolution of the Commission on Elections, giving certain factions of the Nationalista Party the
right to propose election inspectors, is in accordance with section 5.

RULING

The court affirms the constitutionality of section 5 of Commonwealth Act No. 657. It argues that the challenged
provision is connected to the reorganization of the Commission on Elections, the subject expressed in the title of the
Act.

The court upholds the discretion of the Commission on Elections in choosing election inspectors when minority
parties do not qualify. It states that unless there is clear illegality or gross abuse of discretion, the court should not
interfere.

The court emphasizes a broad and practical interpretation of the constitutional requirement that the subject of an act
should be expressed in its title. It argues for a reasonable construction that avoids undue interference with necessary
legislation. The court also acknowledges the Commission on Elections' discretion in making decisions related to
election inspectors and emphasizes that, unless there is clear illegality or gross abuse of discretion, the court should
not interfere. The opinion highlights the importance of recognizing the independent character of the Commission on
Elections and allowing it latitude in decision-making related to elections.

5. Llamado v. Court of Appeals (G.R. L-84850, June 29, 1989)

DOCTRINE
In Llamado v. Court of Appeals (G.R. L-84850, June 29, 1989), the Supreme Court ruled that a judge must not
rewrite a statute, neither to enlarge nor to contract it. Whatever temptations the statesmanship of policy-making
might wisely suggest, construction must eschew interpolation and evisceration. He must not read in any way of
creation. He must not read out except to avoid patent nonsense of internal contradictions. (Underscoring Supplied)

FACTS

Ricardo A. Llamado was Treasurer of Pan Asia Finance Corporation. Together with Jacinto N. Pascual, Sr., President
of the same corporation, petitioner Llamado was prosecuted for violation of Batas Pambansa Blg. 22 in Criminal
Case No. 85-38653, Regional Trial Court of Manila, Branch 49. The two w had co-signed a postdated check payable
to private respondent Leon Gaw in the amount of P186,500.00, which check was dishonored for lack of sufficient
funds.

In a decision dated 10 March 1987, the trial court convicted the petitioner alone, since jurisdiction over the person of
Pascual, who had thoughtfully fled the country, had not been obtained. Petitioner was sentenced to imprisonment for
a period of one (1) year of prison correccional and to pay a fine of P 200,000.00 with subsidiary imprisonment in
case of insolvency. Petitioner was also required to reimburse respondent Gaw the amount of P186,500.00 plus the
cost of suit. petitioner through counsel orally manifested that he was taking an appeal. Having been so notified, the
trial court on the same day ordered the forwarding of the records of the case to the Court of Appeals. While his
Appellant's Brief was being finalized by his then counsel of record, sought advice from another counselor.

On 30 November 1987, petitioner, with the assistance of his new counsel, filed in the Regional Trial Court a Petition
for Probation invoking Presidential Decree No. 968, as amended. The Petition was not, however, accepted by the
lower court, since the records of the case had already been forwarded to the Court of Appeals. Petitioner asked the
Court of Appeals to grant his Petition for Probation or, in the alternative, to remand the Petition back to the trial
court, together with the records of the criminal case, for consideration and approval under P.D. No. 968, as amended.

ISSUE

Whether or not the petition for probation, despite the prior perfection of the appeal, be granted?

RULING

No, the petition for probation should be dismissed.

Under the Probation law of 1976, it is stated that under Section 4(2):
“Probation may be granted whether the sentence imposes a term of imprisonment or a fine only. An application for
probation shall be filed with the trial court, with notice to the appellate court if an appeal has been taken from the
sentence of conviction. The filing of the application shall be deemed a waiver of the right to appeal, or the automatic
withdrawal of a pending appeal.”

In its amendment in December 1977, the said provision amended, and stated as:

“Probation may be granted whether the sentence imposes a term of imprisonment or a fine with subsidiary
imprisonment in case of insolvency. An application for probation shall be filed with the trial court, with notice to the
appellate court if an appeal has been taken from the sentence of conviction. The filing of the application shall be
deemed a waiver of the right to appeal, or the automatic withdrawal of a pending appeal. In the latter case, however,
if the application is filed on or after the date of the judgment of the appellate court, said application shall be acted
upon by the trial court on the basis of the judgment of the appellate court.”

As clearly stated under the subsequent amendment, an application for probation shall be filed with the trial court,
and if an appeal has been taken, the filing of such shall be deemed a waiver. If the appeal is already perfected, then
there is no other recourse but to dismiss the petition for probation, where, The Court of appeals have no jurisdiction
to settle the case.

Courts have no authority to invoke "liberal interpretation' or "the spirit of the law" where the words of the statute
themselves leave no room for doubt or interpretation. The spirit of the law and the intent that is to be given effect are
to be derived from the words actually used by the law-maker, and not from some external and transcending the
words of the legislature.

6. JOINT MINISTRY OF HEALTH-MINISTRY OF LABOR AND EMPLOYMENT ACCREDITATION

COMMITTEE FOR MEDICAL CLINICS v. COURT OF APPEALS (G.R. No 78254, April 25, 1991)

FACTS

The Joint Ministry of Health-Ministry of Labor and Employment Accreditation Committee for Medical Clinics
(Committee) issued Rules and Regulations on June 1, 1983, aimed at establishing, regulating, and upgrading the
standards of medical service and examination for workers seeking overseas employment.
Ermita Medical Center, Inc. received accreditation as an in-house medical clinic to serve Builders and Heavy
Equipment Services Corporation (BHESCO). However, the Committee revoked this accreditation twice, alleging
violations of the Rules and Regulations.

Ermita Medical Center appealed to the Court of Appeals, challenging the Committee's authority to issue and enforce
the Rules and Regulations.

The Court of Appeals declared the Committee's decision null and void. While upholding the validity of the Rules
and Regulations, it ruled that the Committee lacked the authority to directly revoke Ermita Medical Center's
accreditation.

ISSUES

1. Whether the Rules and Regulations issued by the Committee were validly enacted.
2. Whether the Committee had the authority to revoke Ermita Medical Center's accreditation directly.

RULING

1. The Supreme Court, in its decision, emphasized the crucial requirement of publication for the Rules and
Regulations to take effect. Citing the Tañada v. Tuvera case, the Court declared that all statutes, including
rules and regulations, must be published to be effective. Since the Rules and Regulations of the Committee
were never published, they had no force and effect.
2. The Court denied the petition, citing a lack of statutory basis, and set aside the decision of the Court of
Appeals for the same reason.

In the case at bar, laws should be published as a condition for their effectivity which is the doctrine derived from
tañada v. tuvera, reiterated in this case, emphasizes that the requirement for the publication of statutes, including
local laws and private laws, for them to take effect. This rule also applies to presidential decrees and executive
orders, subject to valid delegation of legislative powers. Administrative rules and regulations must be published if
they aim to enforce existing laws through valid delegation. However, interpretative regulations and those of purely
internal nature, as well as letters of instructions to subordinates, are exempt from the publication requirement. The
overall aim is to ensure transparency and accessibility in the legal system.In this specific case, the Supreme Court
applied the doctrine to invalidate the Rules and Regulations issued by the Committee, highlighting the importance of
publication for legal provisions to be enforceable. The Court noted a subsequent administrative order issued in 1990,
revising the Rules and Regulations, but clarified that these new rules were not applicable to the present case, and
their publication status needed verification.