INTERPRETATION OF

WORDS AND PHRASES

Ejusdem Generis
Expressio unius est exclusio
alterius
Reddendo Singula Singulis

Ejusdem Generis
Where a general word or phrase follows
an enumeration of particular and specific
words of the same class or where the
latter follow the former, the general word
or phrase is to be construed to include,
or to be restricted to, persons, things or
cases akin to, resembling, or of the same
kind or class as those specifically
mentioned.

Cu Unjieng Sons, Inc. vs.

Board of Tax Appeals
Held: Court rejected the claim. Otherwise
in the clause compensated for by
insurance or otherwise refers to
compensation due under a title analogous
or similar to insurance.

Cebu Institute of Technology vs.

Ople
Held: Those who were employed on task
or contract basis should be related with
field personnel teachers are not field
personnel and therefore entitled to service
incentive leave benefits.

Cagayan Valley Enterprises vs.

CA
Held: Title clearly shows intent to give
protection to all marked bottles of all lawful
beverages regardless of the nature of their
contents.

National Power Corp. vs. Angas

Held: Judgements involving loans or
forbearance money, goods or credit, these
later specific terms having restricted the
meaning judgments to those of the same
class or the same nature as those
specifically enumerated.

Republic vs. Migrino

Held: Subordinates one who enjoys
close association or relation to the former
President and his wife; not to any
government officer during former
Presidents administration
Close associates restricted the
meaning of subordinates

Limitations of Ejusdem Generis

Rule of ejusdem generis, is not of
universal application; it should use to carry
out, not defeat the intent of the law.

Ejusdem generis rule

not applicable
Commissioner of Internal Revenue v.
American Express
Scope: Statutory provision upon which the
regulation is based is by itself not
restrictive. The scope of the word
services in Sec 102 (b)(2) of the Tax
Code is broad; it is not susceptible of
narrow interpretation.

Ejusdem generis rule

not applicable
Garcia v. Social Security Commission
Held: Court finds no need to resort to
statutory construction. Sec. 28(f) of the
Social Security Law imposes penalty on:
(1) The Managing Head
(2) Directors
(3) Partners, for offenses committed by a
juridical person.

Ejusdem generis rule

not applicable
US v. Santo Nino
Held: The rule of ejusdem generis is only
resorted to only for the purpose of
determining what the intent of the
legislature was in enacting the law.

Ejusdem generis rule

not applicable
Cagayan Valley Enterprises v. CA
Held: Other lawful beverages grants
protection to persons engaged or licensed
to engage in manufacture, bottling, or
selling of soda water, mineral or aerated
waters, cider, milk, cream or other lawful
beverages may not be limited to the same
kind or class as those mentioned.

Ejusdem generis rule

not applicable
Roman Catholic Archbishop of Manila v.
Social Security Commission
Held: The rule of ejusdem generis applies
only when there is uncertainty.

Expressio unius est

exclusio alterius
Express mention of one person, thing or
consequence implies the exclusion of all
others.

Parayno v. Jovellanos
Under Article III of Official Zoning Code of
Calasiao, there were certain distinctions
made by the municipality about the
designation of the gasoline filling station
and that of the gasoline service station as
appearing in Article III, Nos. 21 and 42
Zoning ordinance made a distinction
between gasoline service station and
gasoline filling station

San Pablo Manufacturing Corp.

v. CIR
Held: SPMCs interpretation unduly
enlarged the scope of the exemption
clause. Pursuant to expressio unius est
exclusion alterius rule, statue did not
provide exemption for the materials or
ingredients utilized in manufacturing the
enumerated products in Sec. 168, thus
petitioner is not exempted from millers tax

Coconut Oil Refiners Assn., Inc.

v. Torres
The Subic Special Economic Zone shall
be operated and managed as a separate
customs territory ensuring free flow or
movement of goods and capital within, into
and exported out of the Subic Special
Economic Zone, as well as provide
incentives SUCH AS tax and duty-free
importations of raw materials, capital and
equipment.

Negative-opposite doctrine
Argumentum a contrario - What is
expressed puts an end to that which is
implied.

Chung Fook v. White

Held: Court resorted to the negativeopposite doctrine, statute plainly relates
only to the wife of a NATURALIZED
citizen, not a NATIVE-BORN citizen.
Petition for a writ of habeas corpus filed by
a native-born American citizen was
denied.

Application of
expression unius rule.
Centeno v. Villalon-Pornillos
Held: There was no intent to include
solicitations for religious purposes within
coverage, otherwise it would have been
expressly stated. Expressio unius est
exclusion alterius is applied

Application of
expression unius rule.
Lopez v. CA
Held: Where penalty imposed is other than
public censure, reprimand, or suspension
of not more than one month, or a fine not
equivalent to one month salary, the law
gives the respondent right to appeal

Limitation of
expression unius rule.
Javellano v. Tayo
Analysis: to construe the enumeration as
exclusive or to apply the maxim would
lead to inconvenience, hardship and injury
to public service since much undue
authority is given to the 3 officials

Doctrine of casus omissus

Casus omissus pro omisso habendus est
states that a person, object or thing
omitted from anenumeration must be held
to have been omitted intentionally

Doctrine of last antecedent

Qualifying words restrict or modify only the
words or phrases to which they are
immediately associated. They do not
qualify words or phrases which are
distantly or remotely located.

Doctrine of last antecedent

Qualifying words restrict or modify only the
words or phrases to which they are
immediately associated. They do not
qualify words or phrases which are
distantly or remotely located.

Illustration of
Doctrine of Last Antecedent
Florentino v. Philippine National Bank
Held: Pursuant to proximum antecedens
fiat relatio nisi impediatur sentential, the
court held that backpay certificate holders
can compel government-owned banks to
accept certificates as payment.

People v. Tamani
Held: Should be counted from the
promulgation and not from the receipt of
copy of judgment. Promulgation refers to
judgment, while notice refers to order.

Amadora v. CA
Held: Where the school is academic rather
than technical or vocational in nature,
responsibility for the tort committed by the
student will attach to the teacher in charge
of such student, following the first
provision; except where school is technical
in nature, head shall be responsible