CASES FACTS
Tanada v. Yulo, Juan Tañada, the petitioner, had
G.R. No. L- been appointed as a justice of the
43575, May 31, peace in Alabat, Tayabas, on
1935 December 4, 1911. On
September 8, 1934, he requested
a transfer to the position of
justice of the peace in Perez,
Tayabas, based on "Pursuant to
the provisions of section 206 of
the Revised Administrative
Code." However, he completed
sixty-five years of age on
October 5, 1934. Subsequently,
the Judge of the First Instance of
Tayabas, following instructions
from the Department of Justice,
directed Tañada to cease acting
as the justice of the peace in
Perez, Tayabas. Tañada
surrendered his office under
protest and filed an original
action of quo warranto.
De Castro v. This case involves consolidated
JBC, G.R. No. petitions that challenge the
191002, April appointment of the Chief Justice
20, 2010 of the Supreme Court of the
Philippines. Petitioners Arturo
M. De Castro and John G.
Peralta questioned the
appointment of Renato C.
Corona as Chief Justice by then-
President Gloria Macapagal-
Arroyo. They argued that the
appointment was
unconstitutional because it
violated the ban on midnight
appointments provided for in
Section 15, Article VII of the
1987 Philippine Constitution.
They contended that this ban
extended to appointments in the
Judiciary.
ISSUE
The main issue in this case
revolves around the
applicability of Act No.
3899, which required
certain justices of the
peace who reached the age
of sixty-five to cease
holding office on January
1, 1933, and for new
appointments to be made.
Specifically, the issue is
whether Act No. 3899
applies to justices of the
peace who were appointed
before the approval of the
Act but reached the age of
sixty-five afterward.
Additionally, the case
explores whether a transfer
from one municipality to
other amounts to a new
appointment within the
context of the law.
The main issue in these
cases was whether the ban
on midnight appointments
under Section 15, Article
VII of the Constitution
applied to the appointment
of the Chief Justice of the
Supreme Court.
RULINGS
Act No. 3899 does not apply to justices of the peace who
were appointed before the approval of the Act and who
reached the age of sixty-five after January 1, 1933. The court
interpreted the law based on its plain language and
legislative intent, emphasizing that to alter the statute
through judicial construction would be inappropriate.
A transfer of a justice of the peace from one municipality to
another does not constitute a new appointment but rather a
change of position within the same jurisdiction. This
interpretation aligns with the decision of the United States
Supreme Court in a similar case.
Relevance to Statutory Construction:
This case underscores the importance of adhering to
statutory construction principles. The court emphasized that
legislative intent should be determined from the language of
the statute itself and that judicial construction should not be
used to alter the statute or import words or phrases that the
legislature did not include. The court's decision aligns with
the principle that courts should follow the plain words of a
statute, and that hidden meanings at variance with the
language used should not be sought out. In this case, the
court applied a strict interpretation of Act No. 3899 and did
not insert new elements into the law. This highlights the
fundamental role of statutory construction in interpreting
and applying the law.
The Supreme Court ruled that the ban on midnight
appointments did not apply to the Judiciary, particularly the
appointment of the Chief Justice. The Court held that the
language and intent of the Constitution did not include
judicial appointments in the prohibition against midnight
appointments. Therefore, the appointments of Chief Justices
during the period when the ban on midnight appointments
was in effect were constitutional.
Relevance to Statutory Construction:
In this case, the Court had to interpret the relevant
constitutional provisions to determine the scope and
applicability of the ban on midnight appointments. The
Court relied on principles of statutory construction to
ascertain the legislative intent and the meaning of the
Constitution's provisions. The decision highlights the
importance of interpreting legal texts according to their plain
and clear language, and it provides an example of how
statutory construction principles can be applied to
constitutional issues. The ruling clarifies the scope of the
ban on midnight appointments and upholds the separation of
powers between the executive and judicial branches of
government.
Philippine Porping Regalado worked as a
Scout Veterans security guard for the petitioner,
Security & Philippine Scout Veterans
Investigation Security & Investigation Agency,
Agency, Inc. v Inc., from September 1963 until
NLRC, G.R. his retirement on March 20,
No. 99859, 1989. Regalado formally
September 20, requested the payment of
1996 retirement benefits, but the
company refused and offered
financial assistance instead,
without specifying the amount.
Regalado filed a complaint for
non-payment of retirement
benefits, and the labor arbiter
ruled in his favor. The arbiter
relied on Article 287 of the Labor
Code and other provisions of the
law, arguing that employees who
retired and were not covered by
collective bargaining agreements
(CBAs) or company policies
should receive retirement pay.
The arbiter awarded Regalado
retirement pay equivalent to one-
half month's salary for every year
of service.
The petitioner appealed to the
National Labor Relations
Commission (NLRC), which
affirmed the arbiter's decision.
The NLRC reasoned that
employees were entitled to
retirement benefits even in the
absence of a company retirement
plan or CBA, relying on sections
of the Labor Code and
Implementing Rules.
The petitioner subsequently filed
a petition for certiorari with the
Supreme Court to nullify the
NLRC's decision.
People v Yolanda Santos was found guilty
Santos, G.R. beyond reasonable doubt of
No. 237982, fourteen (14) counts of Qualified
October 14, Theft, defined and penalized
2020 under Article 310, in relation to
Article 308 of the Revised Penal
Code (RPC), as amended. The
charges against Santos stemmed
from her diversions of payments
made by the clients of Dasman
Realty and Development
Corporation on separate
occasions, totaling over One
The main issue in this case
is whether an employee is
legally entitled to
retirement benefits in the
absence of a CBA or
company policy providing
for such benefits.
1. Whether the trial court's
imposition of a single,
indivisible penalty for all
14 counts of qualified theft
is proper.
2. Whether the passage of
R.A. No. 10951, which
affected penalties for theft
and other crimes based on
the value of the subject
matter, should apply
retroactively.
The Supreme Court ruled in favor of the petitioner and set
aside the NLRC's decision. The Court held that there was no
contractual or statutory basis for the grant of retirement
benefits to the private respondent, Porping Regalado.
Relevance to Statutory Construction:
This case is relevant to statutory construction as it revolves
around the interpretation and application of labor laws,
specifically Article 287 of the Labor Code and sections of
the Implementing Rules. The Court clarified that these
provisions do not require the payment of retirement benefits
when there is no retirement plan, CBA, or company policy
in place to provide for such benefits.
The Court's decision underscores the importance of
accurately interpreting statutory provisions. It emphasizes
that statutory construction should consider the clear
language and intent of the law, especially when it comes to
employee benefits and rights. Furthermore, the Court noted
that any doubt in the interpretation of laws should be
resolved in favor of the employees to fulfill the humanitarian
purposes of retirement laws, but this must be done within the
confines of the legal framework. In this case, the absence of
a legal basis for retirement benefits led to the ruling against
their award, highlighting the significance of statutory
interpretation in employment-related matters.
1. The trial court's imposition of a single, indivisible penalty
for all 14 counts of qualified theft is improper. This is
because each occasion of "taking" constitutes a single act
with an independent existence and criminal intent of its own,
and there is no single criminal resolution underlying all
these takings. Therefore, Santos should be sentenced
separately for each count of qualified theft.
2. The passage of R.A. No. 10951, which affected penalties
for theft and other crimes dependent on the value of the
subject matter, should apply retroactively. The law is more
favorable to the accused, and it should be given retroactive
effect.
 Million Twenty-Nine Thousand
Eight Hundred Ninety-Three
Pesos and 33/100
(P1,029,893.33).
Santos was sentenced by the
lower court to reclusion perpetua
for all 14 counts of qualified
theft and ordered to restitute the
aggregate amount of
P1,029,893.33. However, it was
argued that the trial court's
imposition of a single, indivisible
penalty for all 14 counts was
improper, as each "taking" was
considered a single act with an
independent existence and
criminal intent. The accused
claimed that this improper
penalty contravened the new
provisions introduced by
Republic Act No. 10951 (R.A.
No. 10951), which had an impact
on penalties for crimes
dependent on the value of the
subject matter.
Lhuillier v Edna Diago Lhuillier (petitioner)
British filed a complaint for damages
Airways, G.R. against British Airways
No. 171092, (respondent) in the Regional
March 15, 2010 Trial Court (RTC) of Makati
City. The complaint alleged that
during an international flight
from London, United Kingdom
to Rome, Italy, the petitioner was
subjected to alleged ill-treatment
by the airline's flight attendants.
She claimed that a flight
attendant refused to assist her
with her luggage, and another
flight attendant humiliated her
during a lecture on plane safety.
3. How should the
penalties for each count of
qualified theft be
computed based on
statutory construction?
4. Whether the provisions
on penalties for qualified
theft under Article 310 of
the RPC result in unjust,
disparate penalties for theft
offenses of different
values.
1. Whether the Warsaw
Convention, an
international treaty, applies
to the case, determining
the jurisdiction over claims
arising from international
air travel.
2. Whether British
Airways' special
appearance in filing the
motion to dismiss
constituted voluntary
submission to the
jurisdiction of the trial
court.
3. The penalties for each count of qualified theft should be
computed as follows:
For amounts exceeding P20,000 but not exceeding
P600,000, the penalty is prision correccional in its minimum
and medium periods. After applying Article 310's two-
degree higher penalty, it becomes prision mayor medium to
prision mayor maximum.
For amounts exceeding P5,000 but not exceeding P20,000,
the penalty is arresto mayor in its medium period to prision
correccional in its minimum period. After applying Article
310's two-degree higher penalty, it becomes prision mayor in
its minimum period and reclusion temporal in its minimum
period.
4. There is an oversight in Article 310 of the RPC regarding
the penalty for theft involving amounts exceeding P5,000
but not exceeding P20,000. The penalty for this category is
actually higher than that for theft involving amounts
exceeding P20,000 but not exceeding P600,000. This results
from the number of periods in the penalties. It is
recommended that Congress rectify this situation to avoid
unjust and disparate penalties for theft offenses of different
values.
Relevance to Statutory Construction:
This case illustrates the importance of statutory construction
in the interpretation and application of criminal laws. It
highlights the need to analyze the text, context, and purpose
of statutory provisions to ensure that penalties are consistent
with the principles of justice and fairness. Additionally, it
underscores the role of the courts in reporting anomalies in
the law to the legislative branch for necessary amendments.
In this case, the Court recognized that an oversight in the
law led to unjust penalties and recommended that Congress
rectify the situation to achieve a more equitable legal
framework.
The Supreme Court affirmed the RTC's decision, citing the
following:
The Warsaw Convention, an international treaty, has the
force of law in the Philippines and applies to international
air travel. Under the Convention, jurisdiction over cases
arising from international carriage can be in the courts of the
defendant's domicile, principal place of business, the place
where the contract was made, or the place of destination.
Since British Airways' domicile and principal place of
business were in London, and the ticket was purchased in
Rome with Rome as the destination, the case should be filed
in London or Rome, not in the Philippines.
The claims made by the petitioner, based on tortious conduct
during the flight, were still subject to the Warsaw
 The petitioner demanded
significant damages based on
tortious conduct, citing violations
of the Civil Code on Human
Relations.
British Airways filed a motion to
dismiss the case, arguing that the
courts in London, United
Kingdom, or Rome, Italy, should
have jurisdiction over the
complaint, pursuant to the
Warsaw Convention, an
international treaty governing air
travel. British Airways also
contended that the summons was
improperly served, and thus the
trial court lacked jurisdiction.
The RTC granted British
Airways' motion to dismiss,
citing the Warsaw Convention as
binding and stating that the case
should be filed in the appropriate
courts in London or Rome. The
petitioner appealed to the
Supreme Court.
People v The case involves two
Sandiganbayan, consolidated petitions filed by
G.R. No. the Republic of the Philippines.
188165, In G.R. No. 188165, the State
December 11, had raised the issue of
2013 interpreting the term
"transaction" as used in Section
3(b) of Republic Act No. 3019,
which deals with corrupt
practices of public officials. The
State contended that the
Sandiganbayan, a special anti-
corruption court, incorrectly
quashed a criminal case by
restricting the definition of
"transaction" to only those
involving monetary
consideration. In G.R. No.
189063, the State appealed the
Sandiganbayan's decision to
dismiss a criminal case against
certain individuals due to an
alleged inordinate delay in the
proceedings, arguing that this
delay violated the accused
individuals' constitutional right
to a speedy disposition of their
case.
1. In G.R. No. 188165, the
specific issue was whether
the Sandiganbayan
committed grave abuse of
discretion by interpreting
"transaction" restrictively
in line with Soriano, Jr. v.
Sandiganbayan.
2. In G.R. No. 189063, the
issue revolved around
whether the
Sandiganbayan's dismissal
of a criminal case due to
an alleged inordinate delay
in the proceedings violated
the constitutional right to a
speedy disposition of
cases.
Convention, and such claims could not exclude the case
from the Convention's jurisdiction.
British Airways did not voluntarily submit itself to the
jurisdiction of the trial court by raising issues in its
pleadings. The Supreme Court emphasized that a special
appearance to question a court's jurisdiction is not
considered a voluntary appearance, and the defendant does
not waive the objection to jurisdiction.
In summary, the Supreme Court's ruling reaffirmed the
applicability of the Warsaw Convention to international air
travel cases and clarified that raising issues in pleadings
does not constitute voluntary submission to a court's
jurisdiction. The case underscores the importance of
statutory construction when interpreting international
treaties and statutes that impact jurisdictional matters.
Relevance to Statutory Construction:
The case involves statutory construction, particularly the
interpretation and application of the Warsaw Convention, an
international treaty that has the force of law in the
Philippines. Statutory construction is essential in
determining the correct interpretation and application of a
treaty or statute, particularly when it involves issues of
jurisdiction.
G.R. No. 188165 (Interpretation of "Transaction"):
The Supreme Court ruled that the Sandiganbayan correctly
applied the restrictive interpretation of the term "transaction"
as established in Soriano, Jr. v. Sandiganbayan. The court
emphasized that the interpretation in Soriano, Jr. had not
been overturned, and the State's argument that the term
should be construed more liberally was not accepted. The
court explained that statutory construction should take into
account that laws creating, defining, or punishing crimes
should be construed strictly against the state and liberally in
favor of the accused. It held that the Sandiganbayan did not
commit grave abuse of discretion in applying the Soriano, Jr.
interpretation of "transaction."
G.R. No. 189063 (Inordinate Delay and Constitutional
Rights):
In this case, the Supreme Court ruled that the
Sandiganbayan did not commit grave abuse of discretion in
finding an inordinate delay in the resolution of a criminal
case. The court emphasized that the right to a speedy
disposition of cases is a constitutional right that applies to all
cases before judicial, quasi-judicial, or administrative
bodies. It criticized the Office of the Ombudsman for relying
on the ratification of treaties before proceeding with the
preliminary investigation, which led to a significant delay.
The court found that this delay was unreasonable and

Lambino v. Raul L. Lambino and Erico B.
COMELEC, Aumentado, together with
G.R. No. 6,327,952 registered voters, filed
174153, a petition before the Commission
October 25, on Elections (COMELEC) for a
2006 People's Initiative to amend the
1987 Philippine Constitution to
shift from a presidential system
to a parliamentary system of
government.
The petitioners claimed that they
complied with the signature
requirement, specifically that it
was signed by at least 12% of the
total number of registered voters,
with each legislative district
represented by at least 3% of the
registered voters therein.
However, the COMELEC, in a
Resolution dated August 31,
2006, denied due course to the
The main issue in this case
is whether the COMELEC
gravely abused its
discretion in denying due
course to the petition for a
People's Initiative to
amend the Constitution.
constituted a violation of the constitutional rights of the
accused individuals. It also stressed that statutory
construction principles should be observed when
interpreting and applying the law.
Relevance to Statutory Construction:
The relevance of statutory construction in these cases lies in
the interpretation of the term "transaction" in Section 3(b) of
Republic Act No. 3019. The court in G.R. No. 188165
considered the principles of statutory construction,
emphasizing that laws creating, defining, or punishing
crimes should be construed strictly against the state and
liberally in favor of the accused. It held that the restrictive
interpretation established in Soriano, Jr. should be upheld.
In G.R. No. 189063, statutory construction principles were
not directly the main focus. However, the court's
interpretation of the constitutional right to a speedy
disposition of cases and the criticism of the delay in the
proceedings underscore the importance of interpreting and
applying laws in a manner consistent with the principles of
fairness, justice, and due process.
These cases illustrate how statutory construction principles
can impact the interpretation of laws, especially when
constitutional rights are involved. The court's adherence to
the principle that penal laws should be strictly construed in
favor of the accused underscores the importance of
upholding individual rights even in the face of alleged
violations of the law.
The Supreme Court ruled in favor of the petitioners and held
that the COMELEC gravely abused its discretion in denying
the petition. The Court's ruling was rooted in statutory
construction and constitutional law.
Statutory Construction:
The Court held that R.A. No. 6735 was sufficient to cover
initiatives to amend the Constitution. It stated that the
Constitution is the fundamental law, and the enabling law,
R.A. No. 6735, is construed liberally to give effect to the
people's initiative clause in the Constitution.
The term "initiative on the Constitution" found in the
Constitution referred to any amendment of the Constitution.
The law did not need to explicitly state "amendment" to
include it.
Constitutional Law:
The Constitution expressly allows for initiatives to amend
the Constitution, and it imposes the specific numerical
requirements (at least 12% of registered voters, with each
legislative district represented by at least 3% of registered
voters therein).
 petition on the ground that
Republic Act No. 6735 (The
Initiative and Referendum Act)
was insufficient to cover
initiatives to amend the
Constitution.
The COMELEC held that R.A.
No. 6735 required a law passed
by Congress to implement the
exercise of the people's initiative,
which, in this case, was not
present.
Estrada v. In September 1945, Demetria
Caseda, G.R. Estrada filed a case for unlawful
No. L-1560, detainer against Uldarico Caseda.
October 25, She claimed that Caseda leased a
1949 portion of her dwelling for a
monthly rent of P26.
Estrada notified Caseda in
writing on August 11, 1945, to
vacate the premises because one
of her married daughters was
going to occupy the place by the
first of the following month.
Caseda refused to leave.
The main issue was
whether the lessee, Caseda,
should be ejected from the
dwelling leased to him.
The people's exercise of their sovereign right to directly
propose amendments through a People's Initiative is a self-
executing provision that does not require any further
legislation for its implementation. The Constitution is the
highest law and prevails over ordinary statutes.
The COMELEC's duty is to ensure compliance with the
numerical requirements, not to set additional substantive
conditions.
In summary, the Court's ruling emphasized that the
Constitution itself provides for the people's sovereign right
to amend it directly through a People's Initiative. While R.A.
No. 6735 was a valid enabling law, the specific requirements
for amending the Constitution were found in the
Constitution, and these requirements should be strictly
followed without additional conditions. The COMELEC's
denial was thus deemed a grave abuse of discretion.
The municipal court initially ruled in favor of Estrada,
ordering Caseda to pay the rent from October 1, 1945, at the
rate of P26 a month.
However, the Court of First Instance of Manila reversed the
decision, stating that Commonwealth Act No. 689 only
allowed ejectment of a lessee from a dwelling for three
specific reasons: willful and deliberate non-payment of
rents, the lessor's need to occupy the building, and the
lessee's sublease of the building without written consent.
None of these conditions were met.
The Court also addressed the amendment made by Republic
Act No. 66, stating that an amended act should be construed
as if the original statute had been repealed and replaced by
the amended form.
The amended act related back to the date of approval of the
original act, which was October 15, 1945. As Republic Act
No. 66 was approved on October 18, 1946, the four-year
period provided by the amendment expired on October 15,
1949.
Amendment of Statute: The case involved the amendment
of Commonwealth Act No. 689 by Republic Act No. 66. The
Court had to determine how the amended law should be
interpreted in relation to the original statute.
Retroactivity: The Court addressed the issue of whether the
amended law should be applied retroactively. It ruled that
the amended act related back to the date of approval of the
original act. This decision highlights the importance of
understanding when an amendment becomes effective and
whether it should be applied retroactively.

Kida v. Senate. The ARMM regional elections
G.R. No. were supposed to be held on
196271. August 8, 2011. But on June 30,
October 18. 2011, RA No. 10153 was
2011 enacted, resetting the next
ARMM regular elections to May
2013 to coincide with the regular
national and local elections of
the country. RA No. 10153
originated in the House of
Representatives as House Bill
No. 4146, which the House
passed on March 22, 2011, with
191 (of the 285) Members voting
in its favor. The Senate adopted
its own version, Senate Bill No.
2756, on June 6, 2011. 13 (of the
23) Senators voted favorably for
its passage. On June 7, 2011, the
House of Representative
concurred with the Senate
amendments and on June 30,
2011, the President signed RA
No. 10153 into law.
People v. The case involves an appeal from
Manantan, an order of the Court of First
G.R. No. Instance of Pangasinan
14129, July 31, dismissing an information
1962 against the defendant, Guillermo
Manantan. The defendant was
charged with a violation of
Section 54 of the Revised
Election Code. Section 54 of the
Revised Election Code prohibits
certain public officers and
employees from aiding any
candidate or exerting influence in
any manner in an election, except
for voting or preserving public
peace.
During the trial, the defense
moved to dismiss the information
on the grounds that, as a justice
WON No. 10153 amend
RA No. 9054? If so, does
RA No. 10153 have to
comply with the plebiscite
requirements?
The primary issue in the
case is whether a justice of
the peace is included in the
prohibition of Section 54
of the Revised Election
Code. This issue revolves
around the interpretation of
Section 54 and its
application to the
defendant, who is a justice
of the peace.
Continuity of the Law: The Court discussed the principle
that when an amendment leaves certain portions of the
original law unchanged, those portions are regarded as a
continuation of the existing law. This principle is significant
in cases where amendments modify specific provisions
while keeping others intact.
Interpretation of Statutory Grounds: The case also
involved the interpretation of the grounds for ejecting a
lessee from a dwelling as specified in the statute. The Court
clarified that the three specified grounds in the statute should
be strictly followed.
A thorough reading of RA No. 9054 reveals that it fixes the
schedule for only the first ARMM elections;11 it does not
provide the date for the succeeding regular ARMM
elections. In providing for the date of the regular ARMM
elections, RA No. 9333 and RA No. 10153 clearly do not
amend RA No. 9054 since these laws do not change or
revise any provision in RA No. 9054. In fixing the date of
the ARMM elections subsequent to the first election, RA No.
9333 and RA No. 10153 merely filled the gap left in RA No.
9054.
The Supreme Court ruled in favor of the People of the
Philippines and set aside the trial court's order of dismissal.
The case was remanded for trial on the merits. The Court
held that a justice of the peace is indeed included in the
prohibition of Section 54 of the Revised Election Code.
Relevance to Statutory Construction: The case is relevant
to statutory construction as it involves the interpretation of a
statutory provision (Section 54 of the Revised Election
Code) to determine the scope of its application. The Court
engaged in statutory construction to ascertain the legislative
intent behind the provision. Key points of relevance to
statutory construction in the case include:
Use of Generic Terms: The Court analyzed the use of the
term "judge" in Section 54 without any modification. This
was a critical point in the interpretation because it indicated
that the legislature intended to encompass all types of
judges, including justices of the peace, under the broader
term "judge." This underscores the importance of examining
 of the peace, the defendant was
one of the officers enumerated in
Section 54 of the Revised
Election Code. The trial court
initially denied the motion to
dismiss, holding that a justice of
the peace is within the purview
of Section 54. The defense then
cited the decision of the Court of
Appeals in People vs. Macaraeg,
which held that a justice of the
peace is excluded from the
prohibition of Section 54. The
trial court subsequently
dismissed the information
against the accused based on the
Court of Appeals ruling.
Republic v. Daisy R. Yahon (respondent)
Yahon, G.R. filed a petition for a protection
No. 201043, order under Republic Act No.
June 16, 2014 9262 (Anti-Violence Against
Women and Their Children Act
of 2004) against her husband,
S/Sgt. Charles A. Yahon, enlisted
personnel of the Philippine Army
who retired in January 2006. A
Temporary Protection Order
(TPO) was issued by the
Regional Trial Court (RTC),
directing S/Sgt. Yahon to refrain
from threatening or committing
further acts of physical abuse,
stay away from the respondent,
refrain from using or possessing
firearms, and provide reasonable
financial spousal support.
S/Sgt. Yahon did not hire a
counsel, file an opposition, or
answer to the petition.
Subsequently, the RTC allowed
ex-parte presentation of
evidence.
the specific wording and terminology used in a statute to
understand its scope.
Historical Development: The Court considered the
historical development of the law, specifically how the
inclusion of justices of the peace had evolved in earlier
versions of the statute. This historical context aided in
determining the legislative intent behind the provision and
whether justices of the peace were meant to be included.
Executive Department's Interpretation: The Court also
noted that the executive department had interpreted Section
54 to apply to justices of the peace by removing them from
their positions for violating the prohibition. This
administrative interpretation of the law provided additional
support for the Court's statutory construction.
Rules of Statutory Construction: The Court rejected the
application of the rule "expressio unius est exclusion
alterius," emphasizing that the exclusion of a term could not
be inferred when there was no reason for such an exclusion.
This demonstrates the careful consideration of rules of
statutory construction to arrive at the correct interpretation.
In conclusion, the case exemplifies the importance of
statutory construction in legal interpretation and how
legislative intent is determined through a comprehensive
analysis of statutory language, historical context, and
relevant rules and principles of interpretation.
Whether the AFPFC is The Supreme Court upheld the court order. It held that
bound by the court order Section 8(g) of Republic Act No. 9262, being a later
requiring it to withhold enactment, should be construed as an exception to the
50% of S/Sgt. Yahon's general rule that retirement benefits are exempt from
retirement benefits and execution. Section 8(g) provides that a percentage of the
give it directly to the income or salary of the respondent can be withheld by the
respondent as spousal employer and automatically remitted directly to the woman,
support. notwithstanding other laws to the contrary.
The Court found that the exemption from execution of
retirement benefits was not absolute and could be subject to
exceptions provided by later laws. The aim of Republic Act
No. 9262 is to protect women and children from violence,
and the provision of spousal and child support is intended to
address economic abuse. The relief in Section 8(g) is
consistent with this objective and is therefore valid.
The Court also rejected the argument that the military
institution could not be directed to comply with the court
order, as the term "employer" in the law includes both
private and government employers. The court order served
the purpose of ensuring that the respondent receives
financial support as part of the protection order granted
under Republic Act No. 9262.
 The RTC issued a Permanent
Protection Order (PPO), ordering
S/Sgt. Yahon to give spousal
support to the respondent and to
withhold 50% of his retirement
benefits to be given directly to
the respondent. The Armed
Forces of the Philippines Finance
Center (AFPFC) filed a
Manifestation and Motion to Lift
Temporary Protection Order,
arguing that the RTC had no
jurisdiction over the military
institution, and the AFPFC
should not be bound by the court
order.
Hagad v. Gozo- In July 1992, complaints were
Dadole, G.R. filed against local officials in
No. 108072, Mandaue City, including the
December 12, Mayor, Vice-Mayor, and a
1995 Sangguniang Panlungsod
Member, for violating various
laws.
The Deputy Ombudsman for the
Visayas issued a preventive
suspension order against these
local officials.
The local officials argued that the
Ombudsman no longer had
jurisdiction over administrative
complaints against local officials
due to the provisions of the Local
Government Code of 1991,
specifically Sections 60, 61, and
63.
Whether the Ombudsman,
as established under
Republic Act No. 6770
(the Ombudsman Act of
1989), still had the
authority to conduct
administrative
investigations of local
elective officials following
the enactment of Republic
Act No. 7160 (the Local
Government Code of
1991).
Therefore, the AFPFC was bound by the court order to
withhold 50% of S/Sgt. Yahon's retirement benefits and
remit it directly to the respondent as spousal support.
Relevance to Statutory Construction:
This case illustrates the application of statutory construction
principles in interpreting conflicting laws. It highlights the
importance of giving effect to the legislative intent as
expressed in a later law when there is an irreconcilable
conflict with an earlier law. The Court determined that the
later law, Republic Act No. 9262, should prevail and
provided an exception to the general rule that retirement
benefits are exempt from execution. This case underscores
the need to harmonize and give effect to the legislative
purpose behind statutory provisions, even when it appears to
conflict with established principles.
The court ruled in favor of the Ombudsman, stating that the
Local Government Code of 1991 did not repeal the
Ombudsman Act's provisions. The court held that there was
no irreconcilable inconsistency between the two laws, and
thus, the Ombudsman retained jurisdiction to conduct
investigations and impose preventive suspension in
appropriate cases.
Relevance to Statutory Construction:
The case highlights the principle of statutory construction
that repeals of laws by implication are not favored. Courts
must assume the congruent application of existing laws, and
clear incompatibility must be found before inferring an
implied repeal.
The court emphasized that the legislature should be
presumed to have known the existing laws on the subject
and not to have enacted conflicting statutes, showing the
importance of harmonizing laws on the same subject.
The case also discussed the interaction between two laws
that govern similar matters. It highlighted the need to
consider both laws in their entirety, harmonize them, and not
hastily conclude that one repeals the other. The court pointed
out that the Local Government Code merely substituted the
Secretary of Local Government with the Office of the
President but did not divest the Ombudsman of jurisdiction.
The court's decision underscores the importance of adhering
to the text and language of statutes and harmonizing
conflicting provisions when interpreting and applying the
law. It also highlighted the constitutional mandate
supporting the Ombudsman's jurisdiction over public
officials.
The case's decision confirmed the Ombudsman's authority to
conduct investigations and impose preventive suspension on
local elective officials, reaffirming the principle of statutory

Dreamwork Dreamwork Construction, Inc.
Construction v. (petitioner) filed a complaint for
Janiola, G.R. violation of Batas Pambansa
No. 184861, Bilang 22 (BP 22) against Cleofe
June 30, 2009 S. Janiola (private respondent).
Private respondent filed a civil
complaint for the rescission of a
construction agreement and
damages against petitioner.
Private respondent filed a motion
to suspend the proceedings in the
BP 22 case, arguing that the civil
and criminal cases involved
similar facts and issues.
The Metropolitan Trial Court
(MTC) granted the motion,
stating that the resolution of the
civil case might affect the BP 22
case, and it ruled in favor of
private respondent.
Petitioner appealed the MTC's
decision to the Regional Trial
Court (RTC), which upheld the
MTC's decision.
NPC v. Angas, The National Power Corporation
G.R. Nos. (NPC), a government-owned and
60225-26, May controlled corporation
8, 1992 responsible for infrastructure and
development projects, filed two
complaints for eminent domain
against private landowners in
Lanao del Sur. The purpose was
to expropriate certain parcels of
land for hydro-electric power
development and electricity
production.
construction that repeals by implication should not be
presumed unless expressly provided for in the law.
Whether the RTC correctly The Supreme Court ruled in favor of the petitioner, stating
applied the concept of a that no prejudicial question existed. The Court emphasized
prejudicial question and that for a prejudicial question to exist, the previously
ruled in favor of private instituted civil action must involve an issue similar or
respondent, suspending the intimately related to the issue raised in the subsequent
proceedings in the BP 22 criminal action, and the resolution of such issue must
case. determine whether or not the criminal action may proceed.
The Court held that the civil action in this case was
instituted after the criminal action, which contradicted the
requirements set forth in Rule 111, Section 7 of the Rules of
Criminal Procedure. Furthermore, the Court clarified that the
resolution of the civil case regarding the rescission of the
construction agreement was irrelevant to the criminal case
under BP 22, as the elements of the crime did not depend on
the validity of the underlying contract.
In conclusion, the RTC's application of the prejudicial
question concept was incorrect, as the civil case was filed
after the criminal action and its resolution did not impact the
prosecution of the BP 22 case. The Court ordered the MTC
to continue with the proceedings in the BP 22 case.
Relevance to Statutory Construction:
The case highlights the importance of strict adherence to the
elements of a prejudicial question, as specified in the Rules
of Criminal Procedure.
The Court's interpretation of the rule change in the
amendment of Rule 111, Section 7 emphasizes that a civil
action should precede the filing of the criminal action to
create a prejudicial question, thus providing clarity in
statutory construction.
The Court's consideration of the legislative intent behind the
rule change supports the principle of harmonizing seemingly
conflicting laws to form a uniform system of jurisprudence.
This case illustrates the significance of precise statutory
construction in ensuring that legal principles and procedural
rules are correctly applied in specific legal contexts.
Whether or not the legal Yes, the legal rate of interest on just compensation for
rate of interest on just expropriated lands should be determined based on Article
compensation for 2209 of the Civil Code (6% interest rate).
expropriated lands should
be determined based on The court found that Central Bank Circular No. 416 applied
Article 2209 of the Civil only to loans or forbearance of money, goods, or credits, and
Code (6% interest rate). judgments related to such transactions.
In the case at bar, the Supreme Court ruled in favor of the
National Power Corporation (NPC) and held that Article
2209 of the Civil Code should apply since the case involved

The lower court rendered a
consolidated decision,
confirming the lawful
condemnation and expropriation
of the lands and ordering NPC to
pay just compensation "with
legal interest thereon . . . until
fully paid." NPC deposited the
compensation with 6% interest
per annum, but private
landowners sought a 12%
interest rate citing Central Bank
Circular No. 416.
The lower court granted the
landowners' request, and NPC
appealed, arguing that Article
2209 of the Civil Code should
apply, which prescribes a 6%
legal interest rate for obligations
involving payment of money.
Tac-an v. CA, Felipe G. Tac-An, a lawyer, was
G.R. No. L- engaged by the Acopiado
38736 May 21, brothers who faced charges of
1984 frustrated murder and theft of
large cattle in 1960.
Tac-An had the Acopiado
brothers execute a "Deed of
Quitclaim" in April 1960, in
which they transferred a parcel
of land to him as payment for his
legal services, valued at P1,200.
Two days after the deed was
executed, the Acopiado brothers
terminated Tac-An's services,
stating that their wives and
parents did not agree to the land
transfer. They hired another
lawyer.
The Acopiado brothers were
ultimately acquitted of the
charges.
In April 1961, one of the
Acopiado brothers sold his share
of the land to Jesus Paghasian
and Pilar Libetario.
Tac-An appointed an overseer for
the land in June 1964 and
obtained approval from the
Provincial Governor for the
Whether the Deed of
Quitclaim and the land
transfer are valid under the
Administrative Code of
Mindanao and Sulu.
Whether the Provincial
Governor's revocation of
the approval has legal
effect.
Whether Republic Act No.
4252, repealing the
Administrative Code,
affects the case
retroactively.
Whether the nature of the
land as conjugal property
and the lack of spousal
consent affect the validity
of the transaction.
expropriation of land for public use, with no stipulation
regarding interest.
The interest in this case was considered an indemnity for
damages due to the delay in payment, making Article 2209
of the Civil Code applicable. The court rejected the
argument that Central Bank Circular No. 416 impliedly
repealed or modified Article 2209, as the two laws applied to
different situations and transactions that could be reconciled
without conflict.
Therefore, the correct and valid legal interest rate for just
compensation for expropriated lands in this case was 6% per
annum, and the 12% interest rate imposed by the lower court
was annulled and set aside. The injunction against enforcing
the 12% interest rate was made permanent.
The Court of Appeals found that the Deed of Quitclaim was
void due to the Acopiado brothers' non-Christian status as
Subanons and the failure to follow the requirements of the
Administrative Code of Mindanao and Sulu, specifically
Section 145. This section governed the execution and
approval of contracts with non-Christians.
Relevance to Statutory Construction: The court applied
statutory construction by interpreting and applying Section
145 of the Administrative Code of Mindanao and Sulu,
which had substantive legal implications in this case.
The Provincial Governor's revocation of approval had legal
effect, as it was based on the ground that the signature was
obtained through false representation and the non-Christian
vendors were not properly brought before him for
confirmation of the deed. This revocation was considered
valid.
Relevance to Statutory Construction: The court upheld
the revocation based on the substantive grounds specified in
the statute.
Republic Act No. 4252, repealing the Administrative Code,
did not affect the case retroactively. The relevant sections of
the Administrative Code were in force at the time of the
transactions and were substantive in nature, making the
repealing statute inapplicable to past events.
Relevance to Statutory Construction: This demonstrates
the principle that repealing statutes typically do not have
retroactive effects and do not apply to transactions that
occurred before the repeal.
 "Deed of Quitclaim" on July 2,
1964.
On October 7, 1964, Tac-An
filed a complaint in the Court of
First Instance (CFI) of
Zamboanga del Norte, seeking to
be declared the owner of the
land, annul the sale made to
Paghasian and Libetario, and
claim damages and attorney's
fees.
Villegas v. On June 3, 1968, Eduardo Z.
Subido, G.R. Romualdez, Secretary of
No. L-31711, Finance, authorized Jose R.
September 30, Gloria to assume the duties of
1971 Assistant City Treasurer of
Manila, effective June 1, 1968,
following the retirement of
Felino Fineza.
On June 17, 1968, Mayor
Antonio J. Villegas directed Jose
R. Gloria to refrain from
exercising the duties and
functions of the Assistant City
Treasurer, claiming that
Romualdez had no authority to
make such designation.
In response, Villegas appointed
Manuel D. Lapid, the Chief of
the Cash Division of the Office
of the City Treasurer of Manila,
as Assistant City Treasurer,
effective January 1, 1969.
Commissioner of Civil Service
Abelardo Subido disapproved
Lapid's appointment, based on an
opinion from the Secretary of
Justice stating that the
appointment of Assistant
Provincial Treasurers was still
governed by the Revised
Administrative Code and not the
Decentralization Law (Republic
Act No. 5185).
Mayor Villegas and Manuel D.
Lapid filed a special civil action
for prohibition, quo warranto,
The land was presumed to be conjugal property. As the
spouses of the Acopiado brothers did not consent to the
transfer to Tac-An, the transaction was at least voidable.
Relevance to Statutory Construction: The court
considered the legal presumption of conjugal property and
its relevance to the requirement of spousal consent in
transactions involving such property. This was essential for
determining the validity of the transfer.
Conclusion:
The Court of Appeals' decision was upheld, voiding the land
transfer but allowing Tac-An to claim the agreed-upon legal
fee. The case demonstrated the importance of statutory
construction in interpreting and applying laws that have
substantive legal consequences.
Whether Mayor Antonio J. The City Charter of Manila clearly grants the authority to
Villegas has the authority appoint the Assistant City Treasurer to the President of the
to appoint the Assistant Philippines, with the consent of the Commission on
City Treasurer of Manila, Appointments. The provisions of the Charter must be
even though the City upheld, and Mayor Villegas cannot unilaterally appoint the
Charter expressly grants Assistant City Treasurer.
such power to the
President of the The Decentralization Act (Republic Act No. 5185) does not
Philippines. supersede the specific provision in the City Charter
regarding the appointment of the Assistant City Treasurer.
Whether the The Act's general provisions concerning the appointment of
Decentralization Act local employees do not encompass the specific position of
(Republic Act No. 5185) Assistant City Treasurer.
supersedes the specific
provision in the City Implied repeal does not apply in this case, as it is not evident
Charter regarding the that the legislative intent was to repeal the provision in the
appointment of the City Charter. Repeals by duplication are not favored, and
Assistant City Treasurer. there must be a clear and manifest indication of legislative
intent to repeal.
Whether implied repeal is
applicable in this case. Conclusion:
The lower court's decision was affirmed, upholding the
authority of the President of the Philippines to appoint the
Assistant City Treasurer of Manila in accordance with the
City Charter. The Decentralization Act did not override this
specific provision, and there was no implied repeal of the
Charter's appointment authority.
 and mandamus, seeking a
declaration that Romualdez's
authorization of Gloria was
illegal and that Lapid's
appointment be approved by the
Civil Service Commissioner.
University of In this case, the petitioner is the
the Philippines University of the Philippines
v. City (UP).
'Treasurer of On October 27, 2006, UP entered
Quezon City, into a Contract of Lease with
G.R. No. Ayala Land Inc. (ALI). The
214044, June subject matter of the lease was
19, 2019 UP's parcel of land covered by
Transfer Certificate of Title No.
RT-107350 (192689).
According to the contract, UP
would assume payment of real
estate taxes on the land, while
ALI would pay taxes on the
improvements introduced on the
land.
UP and ALI had a development
proposal to create a science and
technology park on the leased
land, which would be used for
research and technology-based
collaborative projects.
Republic Act No. 9500, also
known as the UP Charter of
2008, was enacted on April 29,
2008, providing UP with
significant tax exemptions.
The City Assessor issued a
Notice of Assessment and
Statement of Delinquency,
demanding real property taxes
from ALI based on Sections 205
and 234 of the Local
Government Code.
UP was subsequently issued a
Statement of Delinquency by the
City Treasurer, demanding
payment of real property taxes
for the land it leased to ALI.
People v. Wenceslao Almuete Fernando
Almuete, G.R. Fronda, Fausto Durion, and
No. I-26551, Cipriano Fronda were charged
February 27, with a violation of section 39 of
1976 the Agricultural Tenancy Law in
Whether UP, as a chartered
academic institution with
specific legislated tax
exemptions, is liable for
the real property tax on the
land leased to ALI.
Whether Republic Act No.
9500, as a later law,
supersedes the provisions
of Sections 205 and 234 of
the Local Government
Code and grants UP an
exemption from real
property taxes.
Whether the information
sufficiently alleges the
elements of the offense
under section 39 of the
Agricultural Tenancy Law.
The Supreme Court ruled in favor of UP, granting the
petition.
The Court held that UP is exempt from real property taxes
imposed by the City Treasurer of Quezon City on the land
covered by TCT No. RT-107350 (192689), which is leased
to ALI. The Statement of Delinquency and Final Notice of
Delinquency issued by the City Treasurer were declared
void. The City Treasurer was permanently restrained from
selling the land at public auction to satisfy the tax
delinquency.
Relevance to Statutory Construction:
The case is significant for statutory construction, particularly
regarding the interpretation of laws and their hierarchy.
It underscores the principle that when a later law (in this
case, Republic Act No. 9500) conflicts with earlier laws
(Sections 205 and 234 of the Local Government Code), the
later law prevails. This principle is essential in statutory
interpretation, emphasizing that the most recent legislative
expression of intent takes precedence.
It demonstrates that legislative authority plays a crucial role
in shaping the legal landscape, and specific laws can grant
exemptions or rights that may override general provisions.
The decision highlights how statutory construction can
impact real-life situations, such as tax liabilities for
educational institutions like UP, by clarifying the extent of
their tax exemptions based on a later legislative enactment.
The lower court's order of dismissal was affirmed by the
Supreme Court.
The Court held that section 39 of the Agricultural Tenancy
Law had been repealed by the Agricultural Land Reform
Code of 1963, as amended by Republic Act No. 6389 and as
 a case filed in December 1963 in
Muñoz, Nueva Ecija.
The charges stemmed from the
accused pre-threshing a portion
of their respective harvests of
five (5) cavans of palay each,
without notice to or consent from
their landholder, Margarita
Fernando. The estimated damage
caused to Margarita Fernando
was P187.50 at P12.50 per
cavan.
The accused entered a plea of not
guilty and later filed a motion to
quash the information on various
grounds, including that the
information lacked essential
elements and was deficient. They
claimed there was no law
punishing the act, and the court
had no jurisdiction.
The lower court granted the
motion and dismissed the case,
stating that the information did
not provide sufficient details,
such as the circumstances of the
offense and the date agreed upon
for threshing, and did not
indicate that the palay exceeded
ten percent of the tenants' net
share based on the last normal
harvest.
David v. Alex L. David, in his capacity as
COMELEC, the Barangay Chairman of
G.R. No. Barangay 77, Zone 7, Kalookan
127116, April City and as the President of the
8, 1997 Liga ng mga Barangay sa
Pilipinas, filed a petition to the
Supreme Court. The petition
sought to prohibit the holding of
the barangay election scheduled
for the second Monday of May
1997. David argued that the term
Whether section 39 of the
Agricultural Tenancy Law
had been repealed by
subsequent legislation,
making the charges
invalid.
Whether the term of office
of barangay officials
elected in 1994 should be
three years as per RA 7160
or five years as per RA
6679.
The constitutionality of the
three-year term for
barangay officials as
specified in RA 7160.
implemented by Presidential Decrees Nos. 2, 27, and 316.
Section 39 was premised on the existence of the rice share
tenancy system. The Code of Agrarian Reforms abolished
share tenancy and introduced the leasehold system,
rendering the prohibition against pre-reaping or pre-
threshing obsolete.
The legislative intent not to punish clandestine pre-reaping
and pre-threshing without notice to the landlord was evident,
and the Court held that prosecuting such acts as offenses
under the new law would be inconsistent with its policy and
spirit. As such, the Court affirmed the dismissal.
Relevance to Statutory Construction:
Repeal by Implication: The case demonstrates the principle
that a later law can repeal or supersede an earlier law if it
covers the same subject matter and is intended as a
substitute. In this instance, the Agricultural Land Reform
Code effectively repealed the provisions of the Agricultural
Tenancy Law, even if it did not explicitly do so. The repeal
was implied by the Code's comprehensiveness and intent.
Interpreting Legislative Intent: The Court considered the
legislative intent and spirit of the new law, the Code of
Agrarian Reforms. It considered that the new law abolished
share tenancy and introduced the leasehold system,
rendering certain provisions of the old law inapplicable.
Statutory construction often requires analyzing the context
and purpose of a statute to understand how it should be
applied.
Legislative Declarations: The Court also cited the legal
maxim "cessante ratione legis, cessat ipsa lex," which means
that when the reason for a law ceases to exist, the law itself
becomes obsolete. The legislative declarations in the new
law regarding the change in policy and approach towards
agricultural tenancy provided clear guidance for the Court in
its interpretation.
Overall, this case underscores the importance of
understanding legislative intent, repeals by implication, and
the evolving nature of laws when interpreting statutes and
deciding legal cases.
The Supreme Court denied the petitions, ruling in favor of
the Commission on Elections and the other respondents. The
Court upheld the three-year term for barangay officials as
specified in RA 7160 and rejected the arguments put forth by
the petitioners. The main reasons for the ruling were as
follows:
Legislative Intent: The Court found that the legislative
intent behind RA 7160 was clear and that the law governed
the term of office for barangay officials elected in 1994. The
 of office for barangay officials
elected in 1994 should be five
years, as per RA 6679, rather
than three years as stated in RA
7160. He further claimed that RA
6679 was not repealed by RA
7160 and that the latter's
provisions violated the
constitutional authority of the
legislature to determine the term
of barangay officials.
Laguna Lake The Laguna Lake Development
Development Authority (LLDA) had issued a
Authority v. notice declaring all fish pens,
CA, G.R. Nos. fish cages, and other aquaculture
120865-71 structures in the Laguna de Bay
December 7, Region that were not registered
1995 or for which no application for
registration or permit had been
filed with LLDA as of March 31,
1993, as illegal.
The LLDA had the authority to
issue permits for the use of
surface water, including the
construction and operation of
fish pens in the region.
Subsequently, the affected fish
pen owners filed injunction cases
against the LLDA before various
regional trial courts.
Whether the petitioners
were estopped from
challenging their three-
year terms due to their
participation in the 1994
elections under the
provisions of RA 7160.
The main issue in this case
was to determine whether
the LLDA or the local
municipalities had
jurisdiction over issuing
permits for fish pens, fish
cages, and other
aquaculture structures in
the Laguna de Bay Region.
This issue required
addressing whether the
Local Government Code of
1991 repealed the LLDA's
authority as provided in its
charter, Republic Act No.
4850, which allowed the
LLDA to issue such
permits.
principle that a later law (RA 7160) supersedes an earlier
one (RA 6679) was applied.
Constitutionality: The Court held that the three-year term
for barangay officials, as provided in RA 7160, was
constitutional. The Constitution allows the legislature to
determine the term of barangay officials, and there was no
prohibition on a three-year term.
Estoppel: The Court also found that the petitioners were
estopped from challenging their three-year terms because
they had participated in the 1994 elections under the
provisions of RA 7160. They were barred by their own
actions from claiming a longer term.
In conclusion, the Supreme Court's decision clarified the
term of office for barangay officials elected in 1994,
emphasizing the importance of statutory construction,
legislative intent, and constitutional principles in resolving
conflicting laws.
Relevance to Statutory Construction:
The case involves the interpretation and construction of two
conflicting laws: RA 6679 and RA 7160. Statutory
construction is relevant as the Court needs to determine
which law should prevail based on the legislative intent,
constitutional provisions, and the principle of repealing
earlier laws by later ones. Additionally, the Court must
consider the parliamentary history of these laws to
understand the legislative intent behind the term of office for
barangay officials.
The court ruled in favor of the Laguna Lake Development
Authority (LLDA).
The court held that the Local Government Code of 1991 did
not repeal the provisions of the LLDA's charter. The LLDA
maintained exclusive jurisdiction over the issuance of
permits for fishing privileges within the Laguna de Bay
Region.
The court emphasized that when there is a conflict between a
general law and a special statute, the special statute should
prevail. The LLDA's charter, being a special law, was not
repealed by the general law (Local Government Code of
1991), which dealt with taxing and revenue-raising powers
of local government units.
The LLDA's charter, as a valid exercise of police power,
should prevail over the Local Government Code of 1991 on
matters affecting Laguna de Bay.
The LLDA's authority was necessary for the protection,
conservation, and sustainable development of the Laguna
Lake Region, as well as for lake quality control and

Magtajas v. The case revolves around the
Pryce opposition to the opening of a
properties casino in Cagayan de Oro City,
Corp., G.R. operated by the Philippine
No. 111097, Amusement and Gaming
July 20, 1994 Corporation (PAGCOR). Local
civic organizations, religious
groups, women's associations,
and the youth protested against
the casino, with the City Mayor
and legislators participating in
demonstrations. In response, the
City Council enacted two
ordinances, Ordinance No. 3353
and Ordinance No. 3375-93,
prohibiting the issuance of
business permits for casino
operations and imposing
penalties for violations. Pryce
Properties Corporation
challenged these ordinances,
which led to a decision by the
Court of Appeals declaring the
ordinances invalid.
The primary issue is
whether the local
ordinances prohibiting
casino operations enacted
by the City of Cagayan de
Oro contravene the law,
specifically Presidential
Decree No. 1869 (P.D.
1869) and the Local
Government Code. The
case also delves into the
principles of statutory
construction and the extent
of a local government
unit's power to regulate or
prohibit certain activities.
management. The court concluded that the abrogation of this
power would render the LLDA's reason for being useless
and was not the intent of the Local Government Code of
1991.
Relevance to Statutory Construction:
This case highlights the principles of statutory construction,
where the court interpreted and applied laws to determine
their compatibility. It emphasized that when a special law
(LLDA's charter) and a general law (Local Government
Code) conflict, the special law should prevail unless there
are special circumstances that suggest otherwise.
The case also illustrated the importance of considering
legislative intent when interpreting laws. The court
considered the purpose and mission of the LLDA in
managing the Laguna de Bay Region and concluded that its
authority should be upheld to achieve these objectives.
Statutory construction played a crucial role in resolving the
jurisdictional dispute between the LLDA and local
municipalities, ensuring that the intent and purpose of the
laws were upheld.
The Supreme Court ruled against the local ordinances and
affirmed the Court of Appeals' decision. The Court's key
points include:
Statutory Construction: The Court underscored the
importance of statutory construction, emphasizing that the
legislative branch, rather than the judiciary, has the authority
to determine the legality and scope of gambling activities.
The Court maintained that, unless a statute violates the
Constitution, the judiciary cannot interfere with the
legislature's wisdom in regulating or permitting various
forms of gambling.
Validity of Local Ordinances: The Court set forth the
criteria for determining the validity of local ordinances,
emphasizing that they must not contravene the Constitution
or any statute, must not be unfair, oppressive, or
discriminatory, and must not prohibit, but may regulate,
trade. The Court also emphasized that these ordinances must
be consistent with public policy and should not be
unreasonable.
Interpretation of Statutes: The Court analyzed Section 458
of the Local Government Code, which empowered local
government units to prevent or suppress "gambling and
other prohibited games of chance." It clarified that this
provision referred to illegal gambling only, not activities
authorized by law.
Repeal and Modification: The Court addressed the
argument that the Local Government Code had modified

Gaerlan v. The case revolves around the
Catubig, G.R. 1963 elections for councilors in
No. L-23964, Dagupan City, Philippines.
June 1, 1966 Gregorio V. Gaerlan, Jr., and
Luis C. Catubig were registered
candidates for these positions.
The City Board of Canvassers
proclaimed Catubig as one of the
elected councilors, as he secured
the third-highest number of
votes. However, Gaerlan
contested Catubig's eligibility,
primarily based on Catubig's age.
Catubig was born on May 19,
1939, and at the time of
presenting his certificate of
candidacy, the election, and his
oath-taking as councilor, he was
under 25 years of age, which was
a prerequisite for the office.
Does Gregorio V. Gaerlan,
Jr. have a cause of action
to contest Luis C.
Catubig's eligibility for the
office of councilor?
Which statutory provision,
Republic Act No. 1707 or
Republic Act No. 2259,
governs the age
qualification for the office
of councilor in Dagupan
City?
P.D. 1869 to prevent PAGCOR from operating a casino in
Cagayan de Oro. It held that P.D. 1869 had not been
repealed by the Local Government Code, and there was no
clear intention to do so. The Court pointed out that Congress
retained control over local government units and that the two
laws, P.D. 1869 and the Local Government Code, could be
harmonized.
Relevance to Statutory Construction:
The case exemplifies the principles of statutory construction,
emphasizing the authority of the legislature in enacting and
regulating laws. It highlights the importance of harmonizing
statutes when possible and the limitations on local
government units' powers in conflict with national laws. In
this case, the Court interpreted the language of the Local
Government Code to refer only to illegal gambling and
upheld the authority of PAGCOR, providing a lesson in
interpreting and reconciling statutes to maintain their
coexistence.
The Supreme Court held that Gregorio V. Gaerlan, Jr. had a
cause of action to contest Luis C. Catubig's eligibility for the
office of councilor, despite Gaerlan having no right to the
office even if Catubig were to be ousted. Section 173 of the
Revised Election Code allowed any registered candidate for
the same office to contest the eligibility of the elected
person. The law's language did not require that the
contesting candidate himself would occupy the office if the
action succeeded.
The Court cited the case of Sanchez vs. Del Rosario, which
concerned the same statutory provision, and ruled that the
petitioner's lack of entitlement to the office did not deprive
him of the legal standing to initiate the quo warranto
proceedings.
The Supreme Court ruled that the age qualification for the
office of councilor in Dagupan City should be governed by
Republic Act No. 2259. This decision was based on the
principle of statutory construction and legislative intent.
Republic Act No. 2259, enacted in 1959, provided a uniform
age requirement of 25 years for the position of councilor. In
contrast, Republic Act No. 1707, which amended the
Dagupan City Charter, included a lower age requirement of
23 years.
The Court reasoned that since Dagupan City was not
explicitly excluded from the operation of Republic Act No.
2259 and considering the broad language used in the later
statute, it must take precedence. Moreover, a 23-year-old
councilor could potentially succeed a City Mayor, who was
required to be at least 25 years old, leading to an
inconsistency that was not intended by the law. Therefore,
Catubig was disqualified from holding the office of
councilor due to his age.
In summary, the Supreme Court affirmed the lower court's
judgment, declaring Luis C. Catubig ineligible for the office
of councilor due to his age and ruling that Gregorio V.
Gaerlan, Jr. had the legal standing to contest Catubig's
eligibility, as provided under Section 173 of the Revised
Election Code. This case illustrates the importance of
statutory construction and the determination of legislative
intent in resolving legal disputes.

Relevance to Statutory Construction:

The case of Gregorio V. Gaerlan, Jr. v. Luis C. Catubig is

notable for its application of statutory construction
principles. Statutory construction is the process of
interpreting and analyzing the language and intent of statutes
or laws. In this case, statutory construction played a critical
role in determining the applicable law regarding the age
qualification for the office of councilor in Dagupan City.
Here's how statutory construction was relevant to the case:

Conflicting Statutory Provisions: The central issue in this

case was the conflict between two statutory provisions:
Republic Act No. 1707, which amended the Dagupan City
Charter and set the age requirement for councilors at 23
years, and Republic Act No. 2259, which established a
uniform age requirement of 25 years for councilors in the
Philippines.

Intent of the Legislature: Statutory construction involves

determining the intent of the legislative body that passed the
laws. The Supreme Court analyzed the legislative intent by
examining the language, purpose, and history of the two
statutes. In particular, the Court considered the broad
language of Republic Act No. 2259, which included a
uniform age requirement for councilors throughout the
Philippines.

Consistency and Uniformity: One of the key principles in

statutory construction is that statutes should be interpreted
and applied in a manner that ensures consistency and
uniformity in the law. The Court highlighted the
inconsistency that would arise if a councilor aged 23 could
potentially succeed a City Mayor, who was required to be at
least 25 years old. This inconsistency was not intended by
the law and, therefore, supported the application of Republic
Act No. 2259 as the controlling law.

Repeal of Inconsistent Laws: Statutory construction also

involves determining whether a new law repeals or
supersedes older laws. The Court found that Republic Act
No. 2259, by its broad language, effectively repealed the
lower age requirement in the Dagupan City Charter as it
applied to councilors.

Lagman v. City Benedicto C. Lagman, operating
of Manila, G.R. under the firm name "MARCO
No. L-23305, TRANSIT," held a certificate of
June 30, 1966 public convenience granted by
the Public Service Commission
to operate fifteen auto trucks
with fixed routes for passenger
and freight transport.
The route authorized by the
certificate covered a line from
Bocaue (Bulacan) to Parañaque
(Rizal), passing through various
locations in Manila.
In response to severe traffic
congestion issues, the City of
Manila enacted Ordinance No.
4986 on July 13, 1964. This
ordinance aimed to regulate
provincial passenger buses and
jeepneys' entry into the city and
the routes they could take.
The ordinance designated
specific routes and entry points
for provincial passenger buses
and jeepneys between 6:30 AM
and 8:30 PM.
Benedicto C. Lagman challenged
the ordinance, arguing that it was
unconstitutional, illegal, ultra
vires, and void. He contended
that the routes specified in his
certificate of public convenience
were national roads under the
authority of the Director of
Public Works.
Lagman also asserted that the
city did not have the power to
enact an ordinance that modified
or amended a certificate of
public convenience. He claimed
that such authority was
Whether the City of
Manila had the legal
authority to enact
Ordinance No. 4986,
which regulated the entry
and operation of provincial
passenger buses and
jeepneys within the city,
and whether this ordinance
was constitutional, valid,
and enforceable.
In conclusion, Gregorio V. Gaerlan, Jr. v. Luis C. Catubig
demonstrates how statutory construction principles are used
to interpret and reconcile conflicting laws, identify
legislative intent, and ensure consistency in legal provisions.
In this case, the Court's application of statutory construction
led to the determination that Republic Act No. 2259
governed the age qualification for councilors in Dagupan
City, ultimately impacting the eligibility of the respondent,
Luis C. Catubig, to hold the office of councilor.
The Supreme Court ruled in favor of the City of Manila,
upholding the validity and constitutionality of Ordinance
No. 4986.
Relevance to Statutory Construction:
Special Law vs. General Law: The case addressed the issue
of whether Republic Act No. 409 (the Manila Charter) could
override general laws such as Commonwealth Act No. 548
and the Public Service Act (Commonwealth Act No. 146).
The Court held that Republic Act No. 409, being a special
law and of later enactment, prevailed over the general laws.
This is consistent with the principle that, in cases of conflict,
special laws are deemed exceptions to general laws. The
Court emphasized that special laws should be construed as
exceptions to general laws, especially when there is no
explicit provision indicating otherwise (Cassion vs. Banco
Nacional Filipino, 89 Phil. 560, 561).
Local Government's Authority: The case highlighted the
principle of statutory construction that local government
ordinances and regulations are generally valid and that local
governments possess the power to regulate certain matters
within their jurisdiction. The Court confirmed that the City
of Manila had the legal authority to regulate the entry and
operation of provincial passenger buses and jeepneys within
its boundaries, citing the explicit delegation of police power
to the city's municipal board in its charter (Republic Act No.
409, Section 18 [hh]). It emphasized that such authority was
paramount and superior to other administrative powers
(Commonwealth Act No. 548 and the Public Service Act)
and that the powers of the Public Service Commission were
supplementary to the regulatory powers of local
governments (Commonwealth Act No. 146, Section 17 [j]).
Repeals by Implication: The Court reiterated the principle
that repeals by implication are not favored. It explained that
when a special law is repugnant to or inconsistent with a
prior general law, a partial repeal of the general law will be
implied, or an exception grafted upon it by the special law.
This principle was applied to the relationship between
Republic Act No. 409 and the general laws (Commonwealth
Act No. 548 and Commonwealth Act No. 146) in the context
of regulating provincial passenger buses and jeepneys in
Manila. The Court emphasized that special laws should be
 exclusively vested in the Public
Service Commission.
Furthermore, Lagman argued
that the enforcement of the
ordinance was arbitrary,
oppressive, and unreasonable, as
it severely impacted his business.
JG Summit The case revolves around the
Holdings v. privatization of the Philippine
CA, G.R. No. Shipyard and Engineering
124293, Corporation (PHILSECO). The
November 20, government sought to sell its
2000 shares in PHILSECO, and the
(decision); process involved a public
September 24, bidding.
2003
(resolution of The Joint Venture Agreement
1st MR); (JVA) between KAWASAKI and
January 31, the National Investment and
2005 Development Corporation
(resolution of (NIDC) contained mutual rights
2nd MR) of first refusal, granting each
other the option to purchase
shares before they were offered
to third parties.
J.G. Summit Holdings, Inc., a
losing bidder in the PHILSECO
privatization, argued that the
winning bidder, Philyards
Holdings, Inc. (PHILYARDS),
improperly exercised the right to
top by forming a consortium
with losing bidders to raise the
purchase price.
J.G. Summit also contended that
the right of first refusal should
not apply when PHILSECO
owned land because it would
violate the constitutional limit on
land ownership by corporations.
J.G. Summit further claimed that
PHILYARDS may be in violation
of constitutional restrictions
because it had foreign equity
exceeding 40% and ownership of
long-term leasehold rights.
City of Manila On January 27, 1958, Genaro N.
v. Teotico, G.R. Teotico was waiting for a
No. L-23052, jeepney at the corner of the Old
Luneta and P. Burgos Avenue in
Does the right to top,
sourced from the right of
first refusal, violate the law
or the constitution?
Can the right of first
refusal be validly exercised
when PHILSECO owns
land, potentially exceeding
the constitutional
limitation on land
ownership by
corporations?
Is there a violation of
constitutional restrictions
in terms of foreign equity
or landholdings by
PHILYARDS?
Whether the liability of the
City of Manila is governed
by Section 4 of Republic
Act No. 409 (the Charter
taken as exceptions to general laws unless there are special
circumstances requiring a contrary conclusion.
The right to top, sourced from the right of first refusal, does
not violate the law or the constitution. The court upheld the
mutual rights of first refusal in the JVA and clarified that
converting the right of first refusal to the right to top is
permissible. The court also rejected the argument that the
right to top could not be exercised by a consortium
involving losing bidders.
The court upheld the validity of the right of first refusal,
emphasizing that it is a property right of PHILSECO
shareholders (KAWASAKI and NIDC). The court explained
that the right of first refusal does not, by itself, violate the
constitutional limits on land ownership by corporations. It
can be assigned to a qualified Filipino entity, and the land
ownership limitation applies to the corporation, not the
shareholders.
The court acknowledged the allegations regarding
PHILYARDS' potential violations of constitutional
restrictions on foreign equity and landholdings. However, it
considered these to be questions of fact requiring evidence
and not suitable for resolution at that stage.
Relevance to Statutory Construction:
This case emphasizes the importance of statutory
construction in interpreting laws and constitutional
provisions. In particular, it highlights how statutory
interpretation plays a crucial role in addressing
constitutional questions. The court's rulings in this case
provide guidance on how to reconcile contractual rights (the
JVA) with constitutional limitations, highlighting the
distinction between corporate and shareholder rights and the
need to consider the specific language of the law in question
when evaluating its constitutionality. The case also
underscores the importance of facts and evidence in cases
involving constitutional restrictions, illustrating that
statutory construction should be informed by a clear
understanding of the facts and context in which the laws are
applied.
1. The liability of the City of Manila is governed by Article
2189 of the Civil Code.
January 29, Manila within a "loading and
1968 unloading" zone.
After hailing a jeepney and
attempting to board it, Teotico
fell into an uncovered and
unlighted catch basin or manhole
on P. Burgos Avenue.
The fall caused injuries to
Teotico, including a lacerated
wound on his left upper eyelid,
contusions on various parts of his
body, and other injuries.
He filed a complaint for damages
against the City of Manila, its
mayor, city engineer, city health
officer, city treasurer, and chief
of police, claiming that the city
was negligent in maintaining the
road, which led to his injuries.
Palanca v. CA, On January 22, 1977, petitioner
G.R. No. and Jose S. Sanicas entered into
106685, a Contract to Sell on Installment
December 2, for a parcel of land in the
1994 Philippines, with specified terms.
The contract included a provision
(paragraph 11) that allowed for
an increase in the unpaid balance
in case of monetary fluctuation
of the City of Manila) or
Article 2189 of the Civil
Code.
Whether the City of
Manila can be held liable
for damages even if P.
Burgos Avenue is
considered a national
highway.
Whether the Court of
Appeals' findings
regarding the City's control
or supervision over the
road and its negligence are
subject to review.
Whether the escalator
clause in the contract,
which provides for an
increase in the purchase
price based on monetary
fluctuation, is enforceable.
The Court of Appeals correctly applied the Civil Code,
specifically Article 2189, which addresses the liability of
provinces, cities, and municipalities for damages caused by
defective conditions of roads, streets, and other public works
under their control or supervision.
While Republic Act No. 409 (the Charter of the City of
Manila) is a special law, it establishes a general rule
regulating the liability of the City of Manila for damages
arising from negligence or failure to enforce laws, regardless
of the object of such negligence. Article 2189, on the other
hand, is specific to the defective condition of roads and
streets.
2. The City of Manila can be held liable for damages, even if
P. Burgos Avenue is considered a national highway.
Article 2189 of the Civil Code does not require that the
defective roads or streets belong to the province, city, or
municipality from which responsibility is exacted. What is
required is that the province, city, or municipality has either
control or supervision over the street or road in question. In
this case, the City of Manila had control or supervision over
P. Burgos Avenue.
3. The Court of Appeals' findings regarding the City's
control or supervision over the road and its negligence are
not subject to review.
The determination of these factual issues was made by the
Court of Appeals and is not subject to further review by the
Supreme Court.
Relevance to Statutory Construction:
The case illustrates the relevance of statutory construction in
determining the applicable law and liability in a legal
dispute. It emphasizes that specific provisions of the law,
such as Article 2189 of the Civil Code, can prevail over
general provisions in a special law when dealing with
specific matters, such as the defective condition of roads.
Additionally, it demonstrates that the control or supervision
of public works, as interpreted from the relevant laws, plays
a crucial role in establishing liability for damages in cases
involving municipalities or cities.
The Supreme Court upheld the lower courts' decisions but
on different grounds.
The escalator clause in the contract was found to violate
R.A. No. 529, which mandates that all domestic obligations
in the Philippines must be payable in Philippine currency.
The stipulation allowing payment in a specific foreign
currency or measurement in a foreign currency is against
public policy and void.
 based on the exchange rate of the The Court held that the use of the escalator clause in the
Philippine peso to the U.S. contract, allowing an adjustment based on the exchange rate,
dollar. violated R.A. No. 529. The contract was intended to be
payable in Philippine currency, and the escalation based on
Private respondent Edgardo S. foreign currency was impermissible.
Sanicas assumed the account
from his brother Jose and hired The Court rejected the argument that extraordinary inflation
an accountant to compute his was required for the escalator clause to be enforced, as the
obligations under the contract. contract itself referred to monetary fluctuation, irrespective
of whether it constituted extraordinary inflation.
Edgardo tendered an amount of
P44,955.87 in cash to petitioner, Relevance to Statutory Construction:
including interest. Still,
petitioner refused to accept the This case highlights the importance of statutory construction
payment. in interpreting and applying laws related to the currency and
the legality of contract terms. The Court applied the specific
Edgardo made a judicial provisions of R.A. No. 529, emphasizing that the intent of
consignment of the amount. the parties and the effect of an escalator clause that involves
foreign currency cannot override the law's clear prohibition
Edgardo filed a complaint for on such clauses in domestic obligations. It also underscores
reconveyance with the trial court, the principle that a Central Bank Circular cannot repeal a
seeking to prevent petitioner law, only another law can do so, emphasizing the hierarchy
from canceling the contract and of laws in the legal system.
ejecting him from the property.
He also sought an order for
petitioner to accept the consigned
amount and declare the purchase
price paid in full.

The trial court ruled in favor of

Edgardo, declaring that the
"escalator clause" could not take
effect without "extraordinary
inflation."

The Court of Appeals modified

the judgment, computing the
amount payable by Edgardo to
be P70,688.17, and upheld the
trial court's view that the
escalator clause did not apply
without extraordinary inflation.

Petitioner appealed to the

Supreme Court.

Sameer Joy C. Cabiles (the respondent)
Overseas entered into a contract with
Placement Sameer Overseas Placement
Agency, Inc. v. Agency, Inc. (the petitioner) to
Cabiles, G.R. work as a factory worker in
No. 170139, Taiwan. However, she was
August 5, 2014 illegally terminated by her
foreign employer, Wacoal, before
the expiration of her contract.
Following her termination, the
Is the clause "or for three
(3) months for every year
of the unexpired term,
whichever is less" in
Section 7 of Republic Act
No. 10022
unconstitutional?
What is the liability of
Sameer Overseas
The Supreme Court declared the clause "or for three (3)
months for every year of the unexpired term, whichever is
less" in Section 7 of Republic Act No. 10022 amending
Section 10 of Republic Act No. 8042 as unconstitutional
and, therefore, null and void. The court found that this
clause created an arbitrary and unjust distinction among
overseas workers, and it failed the strict scrutiny test, as it
violated the workers' fundamental right to protection and
equal treatment. The clause subjected overseas workers with
employment contracts of at least one year and with less than
 respondent demanded payment
for the unexpired portion of her
employment contract and
reimbursement for the
NT$3,000.00 salary that Wacoal
had withheld from her. When her
demands were not met, she filed
a complaint against Sameer
Overseas Placement Agency, Inc.
The Labor Arbiter found in favor
of the respondent, ordering the
petitioner to pay her the amount
equivalent to her salary for the
unexpired portion of the
employment contract,
reimbursement for the withheld
salary, and attorney's fees. This
decision was affirmed by the
National Labor Relations
Commission (NLRC) and the
Court of Appeals.
The petitioner appealed to the
Supreme Court, raising various
issues, including the
constitutionality of the clause "or
for three (3) months for every
year of the unexpired term,
whichever is less" in Section 7 of
Republic Act No. 10022
amending Section 10 of Republic
Act No. 8042.
City The case involves the imposition
Government of of a franchise tax on the Manila
San Pablo v. Electric Company (MERALCO)
Reyes, G.R. by the City Government of San
No. 127708, Pablo, Laguna, as specified in
March 25, 1999 Ordinance No. 56, also known as
the Revenue Code of the City of
San Pablo.
MERALCO argued that this tax
was in violation of Act No. 3648,
Republic Act No. 2340, and
Presidential Decree No. 551, and
Placement Agency, Inc.
regarding the claims of the
respondent?
Whether the Local
Government Code of 1991
(RA 7160) repealed the tax
exemptions granted to
MERALCO under Act No.
3648, Republic Act No.
2340, and Presidential
Decree No. 551.
one year left in their contracts to different and
discriminatory computation of money claims.
The Supreme Court affirmed the decision of the Labor
Arbiter, NLRC, and the Court of Appeals, ordering Sameer
Overseas Placement Agency, Inc. to pay the respondent the
amount equivalent to her salary for the unexpired portion of
her employment contract and to reimburse her for the
withheld salary. The court cited Section 10 of the Migrant
Workers and Overseas Filipinos Act of 1995, which
establishes that the foreign employer and the local
employment agency are jointly and severally liable for
money claims, including claims arising from the employer-
employee relationship and damages. The local agency's
performance bond is responsible for these money claims or
damages if they are awarded to the employee. This joint and
several liability ensures that overseas workers can obtain full
compensation for their claims, even when the foreign
employer is difficult to reach due to distance or legal
complications. The ruling highlights the importance of
providing additional protection to overseas workers and
shifting the burden of pursuing the foreign employer to the
local employment agency.
Relevance to Statutory Construction:
This case is relevant to statutory construction as it involves
the interpretation of provisions in Republic Act No. 8042
(Migrant Workers and Overseas Filipinos Act of 1995) and
its amendments under Republic Act No. 10022. The
Supreme Court applied principles of statutory construction
to determine the constitutionality of a specific clause in the
law and to interpret the liability of local employment
agencies and foreign employers regarding money claims of
overseas workers. The court's analysis considered the intent
of the law, the protection of overseas workers, and the
principle of equal treatment under the constitution. The case
demonstrates the importance of statutory construction in
clarifying legal provisions and ensuring that the law aligns
with constitutional principles and protects the rights of
individuals, particularly vulnerable groups like overseas
Filipino workers.
The Supreme Court ruled in favor of the petitioners,
upholding the withdrawal of MERALCO's tax exemptions
under RA 7160.
Relevance to Statutory Construction:
The case involves the interpretation of statutory provisions
within RA 7160 (the Local Government Code of 1991) and
their impact on previously granted tax exemptions.
The Court relied on statutory construction to determine
whether the exemptions were repealed. It considered the
language of Sections 137 and 193 of the Local Government
Code, which explicitly allowed local governments to impose
sought a refund of franchise
taxes it had paid under protest.
The key issue was whether the
Local Government Code of 1991
(RA 7160) had repealed the tax
exemptions previously enjoyed
by MERALCO under Act No.
3648, Republic Act No. 2340,
and Presidential Decree No. 551.
franchise taxes and withdrew exemptions, except for those
specifically enumerated in the Code.
The Court also emphasized the principle that doubts in the
interpretation of municipal fiscal powers should be resolved
in favor of local governments, aligning with the
constitutional policy of local autonomy.
The case illustrates how statutory construction is crucial in
legal decisions, as the Court's interpretation of the Local
Government Code's provisions and their impact on previous
laws determined the outcome of the case. The Court's
interpretation of the law and its application to the specific
case were central to its final ruling.