City of Baguio v.

Marcos
G.R. No. L-26100. February 28, 1969

FACTS:
On July 25, 1961, the Director of Lands in the Court of First Instance of Baguio instituted the reopening of the
cadastral proceedings under Republic Act 931. It is not disputed that the land here involved was amongst those
declared public lands by final decision rendered in that case on November 13, 1922. Respondent Belong Lutes
petitioned the cadastral court to reopen said Civil Reservation Case No. 1 as to the parcel of land he claims and
prayed that the land be registered in his name.
On December 18, 1961, private petitioners Francisco G. Joaquin, Sr., Francisco G. Joaquin, Jr., and Teresita J.
Buchholz registered opposition to the reopening. The petitioners questioned the cadastral court's jurisdiction over
the petition to reopen.

ISSUE:
Whether or not the reopening petition was filed outside the 40 year period preceding the approval of Republic Act
931.

HELD:
Yes. The cadastral proceedings sought to be reopened were instituted on April 12, 1912. Final decision was
rendered on November 13, 1922. Lutes filed the petition to reopen on July 25, 1961. It will be noted that the title
of R.A. 931 authorizes "the filing in the proper court, under certain conditions, of certain claims of titl e to parcels
of land that have been declared public land, by virtue of judicial decisions rendered within the forty years next
preceding the approval of this Act." The body of the statute, however, in its Section 1, speaks of parcels of land
that "have been, or are about to be declared land of the public domain, by virtue of judicial proceedings instituted
within the forty years next preceding the approval of this Act." There thus appears to be a seeming inconsistency
between title and body.

It has been observed that "in modern practice the title is adopted by the Legislature, more thoroughly read than
the act itself. R.A. 931 is a piece of remedial legislation and it should receive blessings of liberal construction. The
court says that lingual imperfections in the drafting of a statute should never be permitted to hamstring judicial
search for legislative intent, which can otherwise be discovered. Republic Act 931, claims of title that may be filed
thereunder embrace those parcels of land that have been declared public land "by virtue of judicial decisions
rendered within the forty years next preceding the approval of this Act." Therefore, by that statute, the July 25,
1961 petition of respondent Belong Lutes to reopen Civil Reservation Case No. 1, GLRO Record No. 211 of the
cadastral court of Baguio, the decision on which was rendered on November 13, 1922, comes within the 40-year
period.

People v. Purisima
G.R. No. L-42050, Nov. 20, 1978

FACTS:
These twenty-six (26) Petitions for Review were filed by the People of the Philippines charging the respective
accused with "illegal possession of deadly weapon" in violation of Presidential Decree No. 9. On a motion to quash
filed by the accused, the three Judges issued an Order quashing or dismissing the Informations, on a common
ground, viz, that the Information did not allege facts which constitute the offense penalized by Presidential Decree
No. 9 because it failed to state one essential element of the crime.

ISSUE:
Whether or not the Informations filed by the petitioners are sufficient in form and substance to constitute the
offense of illegal possession of deadly weapon penalized under PD No. 9.

HELD:
No. The Informations filed by petitioner are fatally defective. The two elements of the offense covered by P.D. 9(3)
must be alleged in the Information in order that the latter may constitute a sufficiently valid charged. The
sufficiency of an Information is determined solely by the facts alleged therein. Where the facts are incomplete and
do not convey the elements of the crime, the quashing of the accusation is in order.

In the construction or interpretation of a legislative measure, the primary rule is to search for and determine the
intent and spirit of the law. Legislative intent is the controlling factor, for whatever is within the spirit of a statute
is within the statute, and this has to be so if strict adherence to the letter would result in absurdity, injustice and
contradictions. Because of the problem of determining what acts fall within the purview of P.D. 9, it becomes
necessary to inquire into the intent and spirit of the decree and this can be found among others in the preamble
or, whereas" clauses.

It is a salutary principle in statutory construction that there exists a valid presumption that undesirable
consequences were never intended by a legislative measure, and that a construction of which the statute is fairly
susceptible is favored, which will avoid all objectionable, mischievous, indefensible, wrongful, evil, and injurious
consequences.




Commissioner of Customs v. Relunia
G.R. No. L-11860. May 29, 1959

FACTS:
The Commissioner of Customs appeals to the decision of the Court of Tax Appeals affirming that the forfeiture of
the electric range in question under Section 1363 (g.) is illegal. The RPS "MISAMIS ORIENTAL"' a unit of the
Philippine Navy was dispatched to Japan to transport contingents of the 14th BCT bound for Pusan, Korea, and
carry Christmas gifts for our soldiers there. It seems that thereafter, it was used for transportation purposes in
connection with the needs of our soldiers there and made trips between Korea and Japan, so that it did not return
to the Philippine until September 2, 1954. While in Japan, it loaded 180 cases containing various articles subject to
customs duties.
In the decision of the Court of Tax Appeals, all the articles were declared forfeited by the Collector of Customs of
Manila for violations of the Customs Law pursuant to Section 1363 (g) of the Administrative Code as an
unmanifested cargo including the aforesaid electric.

ISSUES:
Whether or not a manifest is required of the RPS "MISAMIS ORIENTAL"

HELD:
Yes. Section 1228 of the Administrative Code provides that Every vessel from a foreign port or place must have on
board complete written or typewritten manifests of all her cargo. The court ruled that whether the vessel be
engaged in foreign trade (Section 1221 and 1225, Revised Administrative Code) or not (Section 1228), and even
when the vessel belongs to the army or the navy (Section 1234), the universal requirement from a reading of all
the foregoing provisions is that they be provided with a manifest.

The court also believes that there was no necessity where as in the present case the application of Section 1234 of
the Revised Administrative Code to our navy ships is so clear and manifest, considering that the reasons for
requiring a manifest for transport and supply ships of the army and navy of the United States are and with more
reason applicable to our navy ships to carry out the policy of the government, and because we have complete
control over them. It was therefore held that the RPS "MISAMIS ORIENTAL" was required to present a manifest
upon its arrival in Manila on September 2, 1954.

In conclusion, the court holds that all vessels whether private or government owned, including ships of the
Philippine navy, coming from a foreign port, with the possible exception of war vessels or vessels employed by any
foreign government, not engaged in the transportation of merchandise in the way of trade, as provided for in the
second paragraph of Section 1221 of the Revised Administrative Code, are required to prepare and present a
manifest to the customs authorities upon arrival at any Philippine port.

People v. Manantan
GR L-14129, 31 July 1962 (5 SCRA 684)

Facts:
In an information filed by the Provincial Fiscal of Pangasinan in the Court of First Instance (CFI) of that Province,
Guillermo Manantan was charged with a violation of Section 54 of the Revised Election Code. A preliminary
investigation conducted by said court resulted in the finding of a probable cause that the crime charged was
committed by the defendant. Thereafter, the trial started upon defendants plea of not guilty, the defense moved
to dismiss the information on the ground that as justice of the peace, the defendant is not one of the officers
enumerated in Section 54 of the Revised Election Code. The lower court denied the motion to dismiss, holding that
a justice of the peace is within the purview of Section 54. A second motion was filed by defense counsel who cited
in support thereof the decision of the Court of Appeals (CA) in People vs. Macaraeg, where it was held that a
justice of the peace is excluded from the prohibition of Section 54 of the Revised Election Code. Acting on various
motions and pleadings, the lower court dismissed the information against the accused upon the authority of
the ruling in the case cited by the defense. Hence, the appeal by the Solicitor General.

Issue:
Whether the justice of the peace was excluded from the coverage of Section 54 of the Revised Election Code

Held:
Under the rule of Casus omisus pro omisso habendus est, a person, object or thing omitted from an enumeration
must be held to have been omitted intentionally. The maxim casus omisus can operate and apply only if and
when the omission has been clearly established. The application of the rule of casus omisus does not proceed
from the mere fact that a case is criminal in nature, but rather from a reasonable certainty that a particular person,
object or thing has been omitted from a legislative enumeration. Substitution of terms is not omission. For in its
most extensive sense the term 'judge' includes all officers appointed to decide litigated questions while acting in
that capacity, including justice of the peace, and even jurors, it is said, who are judges of facts. The intention of the
Legislature did not exclude the justice of the peace from its operation. In Section 54, there is no necessity to
include the justice of peace in the enumeration, as previously made in Section 449 of the Revised
Administrative Code, as the legislature has availed itself of the more generic and broader term judge,
including therein all kinds of judges, like judges of the courts of First Instance, judges of the courts of
Agrarian Relations, judges of the courts of Industrial Relations, and justices of the peace. The Supreme Court set
aside the dismissal order entered by the trial court and remanded the case for trial on the merits.