[No. L-10662.

December 14, 1956]

ROQUE SENARILLOS, petitioner and appellee, vs. EPIFANIO HERMOSISIMA, ET AL.,
respondents and appellants
DOCTRINE:
STATUTORY CONSTRUCTION ; COURT’S INTERPRETATION CONSTITUTES PART OF THE
LAW AS OF DATE OF ENACTMENT

FACTS:
This is a case appealing the decision of Court of First Instance of Cebu in favor of the petitioner
Senarillos, issuing a writ of mandamus compelling the respondents Municipal Mayor of Cebú, to reinstate
petitioner to the position of Chief of Police, and declaring null and void his removal from that post x x x.
This case originated when respondent was suspended Senarillos from his position. He was subsequently
investigated by a “Police committee” as provided by Republic Act No. 557 the committee proceeded with
the investigation and issued an adverse decision against the petitioner (April 1952). Said decision was
affirmed by the Commission on Civil Service (August 1952) and later by Civil Service Board of Appeals
(October 1954) upon appeal of the petitioner. On April 1955, petitioner resorted for the Court of First
Instance for relief, which issued the Decision being questioned.
Petitioner raised therein that there’s already a decision by the Court in Festejo vs. Mayor of Nabua (G.R.
No. L-4983. December 22, 1954) it is an established jurisprudence that the investigation of police
officers under R.A. 557 (as distinguished from Sec. 2272 of the Administrative Code) must now be
conducted by council itself, and not by mere committee, and that this issue is no longer open for question.
ISSUE:
Whether or not the “police committee” constituted by the Municipal Council of Sibonga Cebu
has jurisdiction to investigate
RULING:
NO. The “police committee” no longer has jurisdiction to investigate against the petitioner in view of the
newly established jurisprudence (Festejo vs. Mayor of Nabua) wherein the investigation of police officers
must be conducted by the municipal council itself and not by a mere committee.
This embodies the doctrine of Legis interpretato legis vim obtinet wherein the authoritative interpretation
f the Supreme Court of a statute acquires the force of law by becoming a part thereof of the date of its
enactment, since the court’s interpretation merely establishes the contemporaneous legislative intent that
the statute thus construed intends to effectuate.
Hence, the court affirmed the decision of the Court of First Instance with the sole modification on the
reimbursement of the salary of the petitioner.

No. L-19650. September 29, 1966.

CALTEX (PHILIPPINES), INC., petitioner and appellee, vs. ENRICO PALOMAR, in his capacity
as THE POSTMASTER GENERAL, respondent and appellant.
CASTRO, J:
DOCTRINE:
Statutes; Construction defined.—Construction is the art or process of discovering and expounding the
meaning 'and intention of the authors of the law with respect to its application to a given case, where that
intention is rendered doubtful, amongst others, by reason of the fact that the given case is not explicitly
provided for in the law (Black, Interpretation of Laws, p. 1).
FACTS:
Caltex Philippines Inc, appellee corporation conducted a promotional scheme called “Hooded Pump
Contest”. Foreseeing the extensive use of mails in this promotion, appellee wrote a letter to the
Postmaster General requesting to be cleared in advance for mailing, incorporating the contest rules and
endeavored to justify its position that the contest does not violate the anti-lottery provisions of the Postal
Law specifically sections 1954 (a), 1982 and 1983 of the Revised Administrative Code. The same was
declined by Acting Postmaster General, siting therein that the scheme falls within the purview of the said
provisions specifying therein that the scheme constitutes as a “lottery”. Caltex sought for reconsideration
of the said stand stressing therein that there being involved no consideration on the part of any contestant,
the contest was not, under controlling authorities, condemnable as a lottery.
Postmaster maintained his view on the contest. relying on an opinion of the Secretary of Justice. (Opinion
217, Series of 1953) that it is a "gift enterprise" which is equally banned by the Postal Law, and in his
letter of December 10, 1960 not only denied the use of the mails for purposes of the proposed contest but
as well threatened that if the contest was conducted, "a fraud order will have to be issued against it
(Caltex) and all its representatives".
Caltex thereupon invoked judicial intervention by filing the present petition for declatory relief against
Postmaster General Enrico Palomar, praying "that judgmnent be rendered declaring its 'Caltex Hooded
Pump Contest' not to be violative of the Postal Law, and ordering respondent to allow petitioner the use of
the mails to bring the contest to the attention of the public". After issues were joined and upon the
respective memoranda of the parties, the trial court rendered judgment as follows:
"In view of the foregoing considerations, the Court holds that the proposed 'Caltex Hooded Pump Contest'
announced to be conducted by the petitioner under the rules marked as Annex B of the petitioner does not
violate the Postal Law and the respondents has no right to bar the public distribution of said rules by the
mails."
The respondent filed its appeal.
ISSUE:
whether or not the scheme proposed “Caltex Hooded Pump Contest” by the appellee is within the
coverage of the prohibitive provisions of the Postal Law
RULING:
NO. Caltex Hooded Pump Contest does not transgress the provisions of the Postal Law.
The appellant contends that there is no question as to the construction. While appellee raised that the need
for construction of legal provisions is vital in this case. In order to answer the question of whether the
promotional scheme of Caltex violated the provisions of prohibition of the Postal Law.
The Postal Law provides under Section 1982– Fraud Orders - Upon satisfactory evidence that any person
or company is engaged in conducting any lottery, gift enterprise or scheme for the distribution of money
or of any real or personal property by lot x x x… The “lottery” being referred to in this provision is
cleared of by 25 words and phrases perm. Ed. P. 695, which provides that "Gratuitous distribution of
property by lot or chance does not constitute 'lottery', if it is not resorted to as a device to evade the law
and no consideration is derived, directly or indirectly. It clearly states that gift enterprises and similar
schemes therein contemplated are condemnable only if, like lotteries, they involve the element of
consideration which is clearly not present in the promotion scheme of the appellee.
Hence, the Court affirmed the judgment. No cost.

G.R. No. 170735. December 17, 2007.*

 IMMACULADA L. GARCIA, petitioner, vs. SOCIAL SECURITY COMMISSION LEGAL AND
COLLECTION, SOCIAL SECURITY SYSTEM, respondents.

Chico-Nazario, J:

DOCTRINE: Statutory Construction; A simplistic interpretation of the law is untenable—it is a rule in

statutory construction that every part of the statute must be interpreted with reference to the context, i.e.,
that every part of the statute must be considered together with the other parts, and kept subservient to the
general intent of the whole enactment;

FACTS:

Appellant corporation Impact Corporation, represented by its lone shareholder Immaculada L. Garcia
appealing the decision of the Court Appeals dismissing her petition for lack of merit which applied
Section 28(f) of the Social Security Law. Contending therein that the Court of Appeals committed grave
error in holding her solely liable for the collection of the unremitted SSS premium contributions and the
consequent late penalty payments due thereon.

This case arose from the non-remittance of SSS premium contributions of the employees which was being
collected by the Social Security System on it is complaint for collection against Impact Corporation,
appellant invoking therein that the said corporation has already been out of business and that the company
suffered irreversible economic losses.

There is no dispute that the SSS premiums of the employees were already deducted from their salaries by
Impact Corporation under the Social Security Law Sections 18, 19 and 22. Appellant contends that Sec
28(f) of Social Security Law does not include the penalties for the unremitted SSS premiums, but it only
refers to the unpaid SSS premium contributions.

Issue: Whether or not Sec 28(f) includes the liability of corporation in the late filing of SSS contribution

RULING: YES.

Sec 28(f) provides that:

“(f) If the act or omission penalized by this Act be committed by an association, partnership, corporation
or any other institution, its managing head, directors or partners shall be liable to the penalties provided in
this Act for the offense.” Garcia vs. Social Security Commission Legal and Collection, 540 SCRA 456,
G.R. No. 170735 December 17, 2007

If the stated provisions will be interpreted as its own, the provision will provide room for two
interpretations, which is not the intent of the legislation when this was enacted. The Social Security Law
shall be interpreted as a whole in order to clearly know the intent of the legislation. The provisions
elaborating the details in Sec. 28 (f) is clearly stated in Sec. 22 of the same provision.

Petitioner invokes the rule in statutory construction called ejusdem generic; that is, where general words
follow an enumeration of persons or things, the interpretation of petitioner as to Section 28(f) of the
Social Security Law that it was only applicable to penalties and not to the liability of the employer for the
unremitted premium contributions. Respondents present a more logical interpretation that is consistent
with the decisions as a whole and with the legislative intent behind the Social Security Law.

This case embodies the general principle of statutory construction that where the word of a provision is
unclear or vague and warrants multiple interpretation, the statute must be interpreted as a whole in order
to find its true meaning and effect.

Hence, the Court affirmed with Finality the Decision made by the Court of Appeals. Petitioner as sole
surviving director is ordered to pay the collected and unremitted SSS contributions of Impact
Corporation.

[Nos. L-6355-56. August 31, 1953]

Pastor M. Endencia and Fernando Jugo, plaintiffs and appellees, vs. Saturnino David, as Collector
of Internal Revenue, defendant and appellant.
Montemayor, J:
DOCTRINE:
Interpretation of Laws, a Judicial Finction.—The Legislature cannot lawfully declare the collection of
income tax on the salary of a public official, specially a judicial officer, not a decrease of his salary, after
the Supreme Court has found and decided otherwise. "Defining and interpreting the law is a judicial
function and the legis lative branch may not limit or restrict the power granted to the courts by the
Constitution." (Bandy vs. Mickelson et al., 44 N.W., 2nd, 341, 342; see also 11 Am. Jur., 714-715 and
905.) The act of interpreting the Constitution or any part thereof by the Legislature is an invasion of the
well-defined and established province and jurisdiction of the Judiciary.

FACTS:
Decision found and held that under the doctrine laid down by this Court in the case of Perfecto vs. Meer,
85 Phil., 552, the collection of income taxes from the salaries of Justice Jugo and Justice Endencia was a
diminution of their compensation and therefore was in violation of the Constitution of the Philippines,
and so ordered the refund of said taxes.
Congress did not favorably receive the decision in the Perfecto case and promulgated Republic Act No.
590, if not to counteract the ruling in that decision, at least now to authorize and legalize the collection of
income tax on the salaries of judicial officers. We quote section 13 of Republic Act No. 590:
''Sec. 13. No salary wherever received by any public officer of the Republic of the Philippines shall be
considered as exempt from the income tax, payment of which is hereby declared not to be a diminution of
his compensation fixed by the Constitution or by law."
ISSUE:
May the Legislature lawfully declare the collection of income tax on the salary of a public official,
specially a judicial officer, not a decrease of his salary, after the Supreme Court has found and decided
otherwise?

RULING:
NO.
The Constitution particularly in Sec. 1 of Article VIII it clearly states therein that judicial power shall be
vested in one Supreme Court and in such lower courts as may be established by law.
By legislative fiat as enunciated in section 13, Republic Act No. 590, Congress says that taxing the salary
of a judicial officer is not a decrease of compensation. This is a clear example of interpretation or
ascertainment of the meaning of the phrase "which shall not be diminished during their continuance in
office," found in section 9, Article VIII of the Constitution, referring to the salaries of judicial officers.
This is a clear invasion of well-established province and jurisdiction of the Judiciary.
In conclusion we reiterate the doctrine laid down in the case of Perfecto vs. Meer, supra, to the effect that
the collection of income tax on the salary of a judicial officer is a diminution thereof and so violates the
Constitution. We further hold that the interpretation and application of the Constitution and of statutes is
within the exclusive province and jurisdiction of the Judicial department, and that in enacting a law, the
Legislature may not legally provide therein that it be interpreted in such a way that it may not violate a
Constitutional prohibition, thereby tying the hands of the courts in their task of later interpreting said
statute, specially when the interpretation sought and provided in said statute runs counter to a previous
interpretation already given in a case by the highest court of the land.
In view of the foregoing considerations, the decision appealed from is hereby affirmed, with no
pronouncement as to costs.