Zarah Amparado

Princess Lyn C. Watin,

Mary Ann S. Soria
Carmelita Decomotan
Herdee Ytac
Arvin Jay A. Leal
G.R. No. L-42935 February 15, 1935
  An action of quo warranto
 Facts of the case:
Felipe Regalado qualified for the office of justice of the peace of Malinao, Albay, on April
12, 1906. On September 13, 1934, Regalado became sixty-five years of age. As a
consequence, shortly thereafter, the judge of first instance of Albay, acting in accordance
with instructions from the Secretary of Justice, designated Esteban T. Villar, justice of the
peace of Tabaco, Albay, to act as justice of the peace of Malinao, Albay

Regalado surrendered the office to Villar under protest. On December 17, 1934, Villar
qualified as justice of the peace of Malinao, Albay, and entered upon the discharge of the
duties of the office.
 Issue:
whether or not under the provisions of section 203 of the Administrative Code, as amended by
Act No. 3899, the justices of the peace and auxiliary justices of the peace appointed prior to the
approval of the last mentioned Act who reached the age of sixty-five years after said Act took
effect shall cease to hold office upon reaching the age of sixty-five years

 Ruling:
 The court ruled that the natural and reasonable meaning of the language used in Act
No. 3899 leaves room for no other deduction than that a justice of the peace appointed
prior to the approval of the Act and who completed sixty-five years of age on September
13, 1934
 subsequent to the approval of the Act, which was on November 16, 1931, and who by
the law was required to cease to hold office on January 1, 1933, is not affected by the
said Act.
G.R. No. 105276 November 25, 1998
Republic vs CA
Facts :
 This case involved the attempt by the Pasay City
Council to reclaim certain submerged areas
within its territory relying on their own definition
of foreshore land under an old law.
 This reclamation project was opposed by the
Government stating that Pasay City had no
foreshore lands to speak of and that the law and
other administrative issuances they relied on are
not applicable.
 The Court of Appeals upheld the position of City
of Pasay to which the issue was thereafter elevated
to the High Court.
Republic vs CA
Issue:

 Whether or not the Court of Appeals is correct in construing the phrase “foreshore lands” to
include those submerged areas within the peripheral territory of Pasay City.

Ruling:

 The court ruled in the negative.

 When the law speaks in clear and categorical language, there is no reason for interpretation
or construction, but only for application.
 So also, resort to extrinsic aids, like the records of the constitutional convention, is
unwarranted, the language of the law being plain and unambiguous.
 Then, too, opinions of the Secretary of Justice are unavailing to supplant or rectify any
mistake or omission in the law.
 To repeat, the term "foreshore lands" refers to:
The strip of land that lies between the high and low water marks and that is alternately wet
and dry according to the flow of the tide.

If the intention of Congress were to include submerged areas, it should have provided
expressly. That Congress did not so provide could only signify the exclusion of submerge
areas from the term “foreshore lands”
RULES OF PROCEDUE
 Refers to the process of how a litigant would protect
his right through the intervention of the court or any
other administrative body.

 Administrative rules of procedure are generally given

a liberal construction.

 In civil proceedings, the rules are different and even

more so in criminal actions.

 However, be it an administrative, civil or criminal

proceedings – the rules should be read and interpreted
first in their natural and common application
Rules of Procedure
 Rules of procedure should be viewed as mere tools
designed to facilitate the attainment of justice.

 When strong considerations of substantive justice are

manifest in the petition, the strict application of the
rules of procedure may be relaxed, in the exercise of its
equity jurisdiction.
Rules of Procedure
 Rules of procedure must be faithfully followed in
the absence of persuasive reason to deviate
therefrom.
 A word of caution, though, the Supreme Court has
declared that ---the liberality in the application of
rules of procedure may not be invoked if it will
result in the wanton disregard of the rules or
cause undue delay in the administration of
justice. Indeed, it cannot be gainsaid that
obedience to the requirements of procedural rule
is needed if we are to expect fair results
therefrom.