Case Summary: B/Gen. Jose Comendador vs. Gen. Renato S. De Villa (G.R.

No. 96948, August 2, 1991)

Facts: Military officers were charged for their involvement in a failed coup. They
were tried by a General Court Martial (GCM) and wanted to exercise their right to
a peremptory challenge (the right to reject a court member without giving a reason)
as provided by Article 18 of the Articles of War. However, the GCM denied this,
saying the right had been discontinued under Presidential Decree (P.D.) No. 39,
issued during martial law to prevent peremptory challenges.

Issue: Can the officers still exercise their right to peremptory challenge, or was this
right removed under P.D. No. 39?

Held: The Supreme Court ruled that the right to peremptory challenge still exists.
Since martial law ended and military tribunals were dissolved, P.D. No. 39 was no
longer applicable. The Court applied the statutory construction principle: “when
the reason of the law ceases, the law itself ceases” (cessante ratione legis, cessat
ipsa lex). Since the reason for P.D. No. 39—martial law—was gone, the law itself
ceased to be in effect. Thus, the right to peremptory challenge was restored.

Doctrine: When the purpose for a law no longer exists, the law itself becomes
ineffective. In this case, P.D. No. 39, created during martial law, no longer applied
after martial law ended, restoring the officers' right to a peremptory challenge.

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The case digest of Lydia O. Chua vs. The Civil Service Commission involves the
interpretation of Republic Act 6683, or the Early Retirement Law, in relation to the
benefits it grants to government employees. The petitioner, Lydia Chua, argued
that she was entitled to the benefits despite being a co-terminus employee, a
position that typically does not have a fixed term.

The Supreme Court ruled in favor of Chua, finding that there is no substantial
difference between a co-terminus employee and contractual, casual, or emergency
employees. All these positions are tenurial in nature, meaning they have no fixed
term. The Court applied the doctrine of necessary implications, which states that
what is implied in a statute is as much as that which is expressed. This means that
the law should be interpreted to include all provisions necessary to achieve its
purpose, which in this case was to provide benefits to government employees who
retire early.
1

Therefore, the Court concluded that excluding co-terminus employees from the
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benefits of the Early Retirement Law would violate the equal protection clause, as
it would discriminate against a group of employees with similar circumstances.
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The case of City of Manila and Treasurer vs. Judge Gomez involves the legality of
an additional one-half percent realty tax imposed by the City of Manila. The tax
was imposed under Ordinance No. 7125, which was enacted pursuant to the
Special Education Fund Law. The petitioner, Esso Philippines, Inc., challenged the
legality of the tax, arguing that it was not authorized by the city charter or any
other law.

The Supreme Court upheld the legality of the tax, relying on the doctrine of
implications. The doctrine states that what is implied in a statute is as much a part
of it as that which is expressed. The Court found that the Special Education Fund
Law, by prescribing a total realty tax of three percent, impliedly authorized the
augmentation of the pre-existing one and one-half percent realty tax by one-half
percent. Therefore, the additional tax imposed by the City of Manila was valid.

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The case of People vs. Guillermo Manantan involves the interpretation of Section
54 of the Revised Election Code, which prohibits certain government officials
from participating in partisan political activities.

(intention of the Legislature to exclude justices of the peace…)

The defendant, Guillermo Manantan, a justice of the peace, argued that he was not
covered by the prohibition. The trial court initially dismissed the case based on the
principle of expressio unius est exclusion alterius, which states that the express
mention of one thing implies the exclusion of others. However, the Supreme Court
reversed the decision and found that the defendant was indeed covered by the
prohibition.

The Court applied the principle of casus omissus, which states that if a particular
person, object, or thing has been omitted from a legislative enumeration, it is
presumed that the omission was intentional. In this case, the Court found that there
was no reasonable certainty that justices of the peace were intentionally omitted
from the prohibition. The Court concluded that the omission was merely a
substitution of terms and that the rule of expressio unius est exclusion alterius was
not applicable.

***Cassus Omissus does not apply in this sample case because it is the substitution
of terms that has been used.
2

The case of JM Tuason and Co. Inc. et. al. vs. Mariano et. al. demonstrates the
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application of the stare decisis principle in legal construction.

Facts: The case involved a land dispute where Manuela Aquial and Maria Aquial
challenged the validity of a title (OCT No. 735) held by JM Tuason and Co. Inc. et.
al. They claimed the land was fraudulently included in the title.

Stare Decisis and the Decision: The Court ruled in favor of JM Tuason and Co.
Inc. et. al., dismissing the case against them. Here, the Court relied on the principle
of stare decisis, which means "to stand by things decided" (stare decisis et non
quieta movere - follow past precedents and do not disturb what has been settled).
The Court highlighted previous rulings that had already upheld the validity of OCT
No. 735. By applying stare decisis, the Court avoided relitigating a settled issue
and ensured consistency in legal interpretation.

Rationale for Stare Decisis: The Court emphasized the importance of stare decisis
in promoting stability and predictability in the legal system. Reopening settled
matters would waste valuable court resources and create uncertainty for those
relying on past precedents.

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Facts: Rommel C. Arnado, a naturalized U.S. citizen who reacquired his
Philippine citizenship under RA 9225, renounced his U.S. citizenship to run for
mayor in 2010. However, he used his U.S. passport after the renunciation, leading
to his disqualification in the Supreme Court case Maquiling vs. Comelec. Despite
this, Arnado ran again in 2013, but his opponent, Florante Capitan, filed to
disqualify him based on the earlier ruling.

Issues: The main issue was whether Arnado’s use of his U.S. passport after
renouncing his citizenship disqualified him under RA 9225.

Court’s Decision: The Supreme Court upheld Comelec's decision to disqualify

Arnado. The Court ruled that using a foreign passport after renouncing citizenship
cancels the renunciation and disqualifies a candidate from public office.

Stare Decisis: The Court relied on its earlier ruling in Maquiling vs. Comelec,
applying the principle of stare decisis (to follow precedents). The Court did not
deviate from its established decision, reinforcing that once a legal principle is set, it
should not be disturbed unless there’s a strong reason. Arnado's case followed this
doctrine, reaffirming that foreign passport use post-renunciation violates RA 9225
and disqualifies candidates.

The case involves a dispute between a husband and wife, Sgt Yahon and the
3

respondent, regarding the distribution of retirement benefits. The wife obtained a

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Temporary Protection Order (TPO) against her husband, which included an order
for him to provide financial spousal support. Sgt Yahon failed to appear in court or
submit an answer to the charges, resulting in a Permanent Protection Order (PPO)
being granted against him.

The issue in the case was whether Sgt Yahon's retirement benefits from the Armed
Forces of the Philippines (AFP) could be used to fulfill his obligation to provide
financial spousal support to his wife. The AFP Finance Center argued that half of
the retirement benefits were exempt from garnishment due to their military nature.
The petitioner contended that money owed to government employees is generally
not subject to garnishment by creditors.

The court ruled in favor of the respondent, finding that Sgt Yahon's retirement
benefits were subject to the financial spousal support obligation. The court applied
the principle of statutory construction that "when the law does not distinguish, the
court should not distinguish." This means that if the law does not make a specific
exception or distinction, the court should not create one.

In this case, Section 8(g) of Republic Act No. 9262, which deals with the
protection of women against violence and their children, uses the general term
"employer." The court interpreted this term to include military institutions,
meaning that the AFP was considered Sgt Yahon's employer for the purposes of
the law. Therefore, the court concluded that Sgt Yahon's retirement benefits were
subject to the financial spousal support obligation, despite the general rule that
government employee salaries are not subject to garnishment.

The case involved a husband and wife who were going through a divorce. The wife
obtained a court order requiring the husband to pay her financial support. The
husband argued that his retirement benefits from the military could not be used to
pay this support.

The court ruled that the husband's retirement benefits could be used to pay the
support. The court used a principle of law that says if the law does not make a
specific exception, the court should not create one. In this case, the law did not say
that military retirement benefits were exempt from being used for support
payments. Therefore, the court decided that the husband's retirement benefits could
be used to pay the support.

The case involved a man named Juanito Pilar who ran for a local government
position but later withdrew his candidacy. After withdrawing, Pilar was fined by
the COMELEC for failing to file a statement of contributions and expenditures.
Pilar argued that he could not be fined because he was no longer a candidate.
4
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The court ruled that Pilar could still be fined even though he had withdrawn his
candidacy. The court used a principle of law that says if the law does not make a
specific exception, the court should not create one.

In this case, the law did not say that candidates who withdrew their candidacy were
exempt from the requirement to file a statement of contributions and expenditures.
Therefore, the court decided that Pilar could still be fined.

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The case involved a man named Guildo Tugonon who was convicted of a crime.
Tugonon appealed the conviction but also applied for probation, which is a
program that allows certain convicted criminals to avoid going to prison.

The law says that if a person appeals their conviction, they cannot also apply for
probation. However, the trial court granted Tugonon's application for probation.

The Supreme Court ruled that the trial court was wrong. The court used a principle
of law that says if the law does not make a specific exception, the court should not
create one. In this case, the law did not say that some appeals were allowed and
others were not. Therefore, the court decided that Tugonon could not apply for
probation because he had appealed his conviction.

The case involved a man named Cecilio de Villa who was charged with a crime
related to a bad check. The check was written in dollars, and de Villa argued that
the law did not apply to checks written in foreign currency.

The court ruled that the law did apply to checks written in foreign currency. The
court used a principle of law that says if the law does not make a specific
exception, the court should not create one. In this case, the law did not say that
checks written in foreign currency were exempt from the law. Therefore, the court
decided that de Villa could be charged with the crime.

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PP v Evangelista and Guildo Tugonon

The case involved a person convicted of frustrated homicide who sought probation.
The law prohibits probation for those who have appealed their conviction. The
court granted probation, but the Supreme Court reversed the decision, stating that
5

the law makes no distinction between meritorious and unmeritorious appeals.

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Therefore, the court should not have granted probation.

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Cecilio de Villa vs CA

The case involved a person who was charged with violating the Bouncing Check
Law (BP 22) for issuing a check that was dishonored due to insufficient funds. The
check was drawn against a foreign bank account. The accused argued that the law
did not apply to foreign checks. The court ruled that the law does apply to foreign
checks because it does not make any distinction based on the currency.

Colgate-Palmolive, Inc…

The case involved a company that imported materials for use in making toothpaste.
The company claimed a refund of the 17% special excise tax on foreign
exchange used for the importation. The government denied the refund, arguing
that the tax was not exempt for toothpaste ingredients.

The court ruled in favor of the company, finding that the law did not exclude
toothpaste ingredients from the list of exempt items. The court applied the
principle of statutory construction that general terms should not be restricted by
specific words if the specific words do not all pertain to one class.

Tecson…

The case involved a dispute between the Philippine government and a retired
military officer named Troadio Tecson. The government accused Tecson of
corruption and sought to prosecute him. Tecson argued that the government did not
have the authority to investigate or prosecute him.

The Supreme Court ruled in favor of Tecson. The Court applied the principle of
ejusdem generis, which states that when general words follow a list of specific
examples, the general words should be interpreted to refer to things of the
same kind or class as the specific examples.

In this case, the Court found that the term "subordinate" in the executive orders
that gave the government authority to investigate and prosecute officials was
limited to those who were closely associated with former President Marcos. The
Court concluded that Tecson did not fit this definition and that the government
therefore did not have the authority to prosecute him.

PP v Echavez
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The case involved a dispute over the application of a law that penalized
squatting.

The government accused sixteen people of squatting on agricultural land. The

trial court dismissed the charges, ruling that the law did not apply to agricultural
land. The government appealed the decision.

The Supreme Court upheld the trial court's decision. The Court applied the
principle of ejusdem generis, which states that when general words follow a list of
specific examples, the general words should be interpreted to refer to things of the
same kind or class as the specific examples.

In this case, the Court found that the law was intended to apply only to squatting in
urban areas, not to squatting on agricultural land. Therefore, the Court concluded
that the trial court had correctly dismissed the charges.

Alta Vista Golf and Country Club v the City of Cebu

The case involved a dispute between Alta Vista Golf and Country Club and the
City of Cebu over the imposition of an amusement tax on golf courses. The City of
Cebu enacted a tax ordinance imposing a 20% tax on the gross receipts of golf
courses from entrance and admission fees. Alta Vista Golf and Country Club
challenged the legality of the tax and refused to pay. The City of Cebu issued a
closure order against the golf course.

Alta Vista Golf and Country Club filed a lawsuit against the City of Cebu, arguing
that the amusement tax was illegal and unconstitutional. The lower court dismissed
the case, but the Supreme Court reversed the decision. The Supreme Court ruled
that golf courses are not places of amusement and therefore are not subject to the
amusement tax.

The Supreme Court ruled that Section 42 of the Cebu City Tax Ordinance,
imposing an amusement tax on golf courses, was null and void.

The Court declared that golf courses cannot be considered places of amusement as
they do not involve the staging of shows or performances.

The Court ordered the City of Cebu to refund or credit the amount paid by Alta
Vista Golf and Country Club as amusement tax.

The Alta Vista Golf and Country Club case can be related to the statutory
7

construction rule of ejusdem generis. This rule states that when general words
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follow a list of specific examples, the general words should be interpreted to refer
to things of the same kind or class as the specific examples.

In the Alta Vista case, the Cebu City Tax Ordinance imposed an amusement tax on
"places of amusement." The Court analyzed the definition of "places of
amusement" and found that it included specific examples such as theaters,
cinemas, and circuses. The Court then applied the ejusdem generis rule to conclude
that the term "places of amusement" did not include golf courses, as golf courses
are not of the same kind or class as theaters, cinemas, and circuses.

Therefore, the Court ruled that the amusement tax imposed on golf courses
was illegal and unconstitutional because it did not fall within the scope of the
statutory definition of "places of amusement."

Municipality of Nueva Era, Ilocos, Norte v CA

The case involved a boundary dispute between the municipalities of Marcos and
Nueva Era in Ilocos Norte, Philippines. The dispute arose over the interpretation of
a law that created the Municipality of Marcos. The law specifically named the
barangays that would comprise Marcos, but did not mention any barangays from
Nueva Era.

The Supreme Court applied the statutory construction rule of expressio unius est
exclusio alterius, which means that the express mention of one thing implies the
exclusion of others. The Court concluded that because the law specifically named
the barangays that would comprise Marcos, and Nueva Era's barangays were not
included, Nueva Era's territory was excluded from the Municipality of Marcos.

Therefore, the Supreme Court ruled that the Municipality of Marcos did not have
the right to claim any part of Nueva Era's territory.
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BUENASEDA VS FLAVIER

The case can be related to the statutory construction principle of expressio unius
est exclusio alterius, which means that the express mention of one thing implies the
exclusion of others.

In the case, the Ombudsman Act grants the Ombudsman the authority to suspend
any officer or employee under his authority pending an investigation if the
evidence of guilt is strong and certain conditions are met. The Act does not
8

specifically mention the power of the Ombudsman to suspend employees of the

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National Center for Mental Health.

However, the Court applied the principle of expressio unius est exclusio alterius to
conclude that because the Act specifically grants the Ombudsman the power to
suspend officers and employees under his authority, this implies that the
Ombudsman does not have the power to suspend employees of the NCMH. The
Court reasoned that if the legislature had intended to grant the Ombudsman the
power to suspend NCMH employees, it would have explicitly mentioned this
power in the Act.

Therefore, the Court ruled that the Ombudsman's suspension of the NCMH
employees was illegal because the Ombudsman did not have the authority to
suspend them.

============================

The case discusses the Ombudsman's power to preventively suspend public

officials or employees facing administrative charges. The Ombudsman has the
authority to suspend such individuals if the evidence of guilt is strong and certain
conditions are met. This power is considered procedural, not penal, and is intended
to aid in the investigation of administrative charges.

The Supreme Court applied the statutory construction rule of noscitur a sociis,
which means that a word should be interpreted based on the words associated with
it. In this case, the Court analyzed the words associated with "suspension" in the
Ombudsman Act and found that they referred to penalties in administrative cases.
Therefore, the Court concluded that the Ombudsman's power to suspend should
also be considered a penalty.

The Court also considered the purpose of the Ombudsman Act, which is to give the
Ombudsman the powers necessary to perform his duties effectively. The Court
found that the power to preventively suspend is necessary for the Ombudsman to
conduct investigations efficiently and to prevent tampering with evidence or
intimidation of witnesses.

Therefore, the Court ruled that the Ombudsman has the power to preventively
suspend public officials or employees facing administrative charges, but only if the
evidence of guilt is strong and certain conditions are met. The Court also
emphasized that the suspension should be considered a penalty and should be
imposed as an aid in the investigation of the administrative charges.

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FULE V CA
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The case involved Manolo Pule, who was convicted of violating the Bouncing
Checks Law. Pule was convicted based on a stipulation of facts that he had signed
during a pre-trial conference. Pule appealed the conviction, arguing that the
stipulation was inadmissible because it was not signed by both him and his
counsel.

The Supreme Court ruled in favor of Pule. The Court applied the statutory
construction rule that negative words and phrases are mandatory, while affirmative
ones are merely directory. The Court found that the rule requiring the stipulation of
facts to be signed by both the accused and his counsel was mandatory and that the
omission of signatures rendered the stipulation inadmissible.

The Court ordered the case to be reopened so that the prosecution could present
independent evidence to establish Pule's guilt. The Court emphasized that penal
statutes should be strictly applied against the government and liberally in favor of
the accused.

BERSABAL V SALVADOR (CFI)

The case involved a dispute between Purita Bersabal and the Court of First
Instance of Caloocan City over the dismissal of her appeal. The Court of First
Instance dismissed the appeal because Bersabal failed to submit a memorandum on
time.

The Supreme Court reversed the decision of the Court of First Instance. The Court
applied the statutory construction principle that the word "may" is permissive,
while the word "shall" is imperative. The Court found that the law allowed parties
to choose whether to submit a memorandum, and that the Court of First Instance
was not required to dismiss the appeal solely because Bersabal failed to submit a
memorandum.

The Court ordered the Court of First Instance to decide the case on the merits
based on the evidence and records that were already in the court's possession. The
Court emphasized that the failure to submit a memorandum should not deprive a
litigant of the right to appeal…and that a court should not dismiss an appeal unless
there is a compelling reason to do so.

Office of the Ombudsman vs. De Sahagun

The case involved a dispute between the Office of the Ombudsman and the Court
of Appeals regarding the Ombudsman's power to investigate and penalize
10

government officials. The Ombudsman had investigated and found guilty

government officials involved in contracts entered into without public bidding. The
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Court of Appeals had set aside the Ombudsman's decision, arguing that the
Ombudsman only had recommendatory powers.

The Supreme Court ruled in favor of the Ombudsman. The Court applied the
statutory construction principle that the word "may" is permissive, while the word
"shall" is imperative. The Court found that the law granting the Ombudsman the
power to investigate and penalize government officials used the word "may,"
which indicated that the Ombudsman had the discretion to exercise this power.

Therefore, the Court concluded that the Ombudsman had the authority to
investigate and penalize the government officials involved in the case. The Court
reversed the decision of the Court of Appeals and reinstated the Ombudsman's
order.

Case Digest: Loyola Grand Villas Homeowners (South

Association Inc vs CA, GR No. 117188

Issue: Is the failure to file LGVHAI’s by-laws within the period

prescribed by Sec. 46 of the Corporation Code had the effect of
automatically dissolving the said corporation.

Decision: No, ordinarily the word “must” connotes

imposition of duty which must be enforced however, the
word “must” in a statute, (like “shall”) is not always
imperative. It may be consistent with an exercise of
discretion. If the language of a statute, considered as a
whole with due regard to its nature and object, reveals that
the legislature intended to use the words “shall” and
“must” to be directory, they should be given that meaning.

The case involved Loyola Grand Villas Homeowners Association (LGVHAI),

which was organized as the sole homeowners' association for Loyola Grand Villas.
However, LGVHAI failed to submit its by-laws within the prescribed period as
required by the Corporation Code. As a result, the corporation was dissolved and
two other associations were formed.
11

LGVHAI appealed the decision to dissolve the corporation. The Supreme Court
ruled in favor of LGVHAI, finding that the failure to submit by-laws within the
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prescribed period did not automatically dissolve the corporation.

The Court applied the statutory construction principle that the word "must" is not
always imperative and can be interpreted as directory. The Court considered the
language of the statute as a whole and found that the legislature intended the word
"must" to be directory in this context.

The Court concluded that while by-laws are important for the orderly management
of corporations, failure to submit them within the prescribed period does not
necessarily result in the dissolution of the corporation.

ROOS INDUSTRIAL CONSTRUCTION INC. V NLRC

The case involved a dispute between Roos Industrial Construction, Inc. and Jose
Martillos over Martillos' employment status and entitlement to benefits. Martillos
filed a complaint for illegal dismissal and money claims, alleging that he had been
a regular employee of Roos. Roos contended that Martillos was a project employee
and that his employment was coterminous with the duration of the projects.

The Labor Arbiter ruled in favor of Martillos, finding that he had acquired the
status of a regular employee. Roos appealed the decision to the NLRC but failed to
post the required cash or surety bond within the reglementary period. Instead, Roos
filed a motion for extension of time to submit/post the surety bond.

The Supreme Court applied the statutory construction principle that the word
"only" is restrictive and excludes other possibilities. In this case, the Court found
that the law required the appellant to post the required cash or surety bond within
the reglementary period and that the word "only" in the law excluded the
possibility of extending the time for posting the bond.

Therefore, the Court ruled that Roos' appeal was dismissed due to its failure to post
the required cash or surety bond within the reglementary period. The Court
emphasized that the word "only" in the law was clear and unambiguous and that
there was no room for interpretation.

PNB V CA

The case involved a dispute between a bank (petitioner) and a borrower (private
respondent) over the foreclosure of a mortgage. The bank foreclosed the mortgage
and sold the property at auction. The borrower argued that the bank did not comply
with the legal requirements for publishing the notice of auction sale.

The law required the notice to be published "once a week for at least three
12

consecutive weeks." The bank published the notice on March 28, April 11, and
April 12. The issue was whether the publication was "once a week" as required by
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the law.
The Supreme Court applied the statutory construction principle that the term
"week" means a period of seven consecutive days. The Court found that the bank
did not comply with the law because the publication on April 12 was not within the
same week as the publication on April 11. Therefore, the Court ruled that the
foreclosure was invalid.

ALU-TUCP V CA

The case involved a group of employees who worked for the NSC. The employees
argued that they were regular employees, while NSC claimed that they were
project employees. The issue was whether the employees were properly classified
as project employees.

The Supreme Court applied the statutory construction principle that the function of
a proviso is to limit or qualify the general language of a statute. In this case, the
Court found that the law defined two types of projects: those within the regular
business of the employer and those that are not. The Court also found that the
employees in this case were hired for projects that were not within the regular
business of NSC and that had a determined duration.

Therefore, the Court concluded that the employees were properly classified as
project employees. The Court rejected the argument that the employees should be
considered regular employees because they had worked for NSC for more than six
years. The Court found that the provision of the labor law regarding the
regularization of employees after one year of service applied only to casual
employees, not project employees.

CHAPTER V

Aris Inc v NLRC

The case involved a dispute between Aris (Phil.) Inc. and an employee who was
reinstated by the Labor Arbiter. Aris appealed the decision, but the employee was
allowed to return to work pending the appeal. Aris argued that this was
unconstitutional, but the Supreme Court upheld the constitutionality of the law.

The Supreme Court applied the statutory construction principle of presumption of

constitutionality. This principle states that laws are presumed to be constitutional,
and that the burden of proving that a law is unconstitutional is on the party
challenging the law.
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In this case, the Court found that the petitioner failed to provide clear and
convincing evidence that the law violated the Constitution. Therefore, the Court
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upheld the constitutionality of the law.

The Court also emphasized the importance of protecting the livelihood of
dismissed employees. The Court found that the law allowing for execution pending
appeal was a valid exercise of the State's police power.

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LIM V PACQUING

The case involved a dispute between the government and Associated Development
Corporation (ADC) over the operation of a jai-alai facility in Manila. The
government argued that ADC's franchise to operate the jai-alai facility had been
revoked by a presidential decree. ADC argued that the decree was unconstitutional.

The Supreme Court ruled in favor of the government. The Court applied the
statutory construction principle of presumption of constitutionality, which states
that laws are presumed to be constitutional unless proven otherwise. The Court
found that there was no evidence to suggest that the decree was unconstitutional.

The Court also rejected ADC's argument that the government was estopped from
challenging the validity of the franchise. The Court stated that the government
cannot be estopped by the mistakes or errors of its officials or agents.

Estafa…Jovencio & Teresita Lim

The case involved a couple who were charged with estafa for issuing a bad check.
The couple argued that the law increasing the penalties for estafa was
unconstitutional. The Supreme Court ruled that the law was constitutional.

The Court applied the statutory construction principle of presumption of

constitutionality, which states that laws are presumed to be constitutional unless
proven otherwise. The Court found that the couple failed to provide clear and
convincing evidence that the law violated the Constitution.

The Court also found that the law did not violate the due process clause of the
Constitution. The Court noted that the law was published in the Official Gazette,
which is an essential requirement for the validity of laws.

Therefore, the Court upheld the constitutionality of the law and dismissed the
couple's petition.
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SALVACION V CENTRAL BANK

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The case involved a foreign tourist named Greg Bartelli y Northcott who was arrested in the
Philippines and charged with serious crimes against petitioner, Karen Salvacion. The court
granted a writ of attachment against Bartelli's dollar account with China Bank. China Bank
invoked a law that protected foreign currency deposits from attachment.

The Supreme Court ruled that the law did not apply to Bartelli's account because he was a
foreign transient. The Court applied the statutory construction principle that the intention of the
lawmaking body is presumed to be right and just. The Court found that applying the law to
Bartelli would result in injustice and inequality.

Therefore, the Court ruled that Bartelli's dollar account could be attached to satisfy the judgment
against him.

ALONZO V INTERMEDIATE APPELLATE COURT

The case involved a dispute between the Alonzo family and the other heirs of a deceased couple
over the redemption of a piece of land. The Alonzos had purchased two shares of the land from
two of the siblings. The other siblings, who lived on the land, filed a complaint for redemption
after 13 years.

The trial court dismissed the complaint, finding that the 30-day period for filing for redemption
had lapsed. The Court of Appeals affirmed the decision.

The Supreme Court upheld the decision of the Court of Appeals. The Court applied the statutory
construction principle that a law should not be interpreted so as to cause an injustice. The Court
found that although the law required a written notice of sale to trigger the 30-day redemption
period, the circumstances of the case indicated that the siblings likely had actual knowledge of
the sale. The Court also found that it would be unfair to allow the siblings to redeem the land
after 13 years, especially since the Alonzos had built a house and fence on the land.

Therefore, the Court ruled that the trial court had correctly applied the law and that the siblings'
claim for redemption was barred by prescription.

Almadovar vs. Pulido-Tan

The case involved a dispute between the General Manager of Isabela Water District (ISAWAD)
and the Commission on Audit (COA) over certain payments made by the GM. The COA
disallowed the payments, finding that they violated various laws and regulations. The GM
appealed the decision to the Supreme Court.

The Supreme Court upheld the COA's decision. The Court ruled that the salary increase for the
GM was improper because it violated the Salary Standardization Law. The Court also ruled that
the engagement of private lawyers by ISAWAD was unauthorized because it did not have the
required written concurrence from the COA. Finally, the Court ruled that the payment of
representation and transportation allowances (RATA) to the GM was excessive.

The Court applied the statutory construction principle of implied repeals. This principle states
that if two laws conflict, the later law repeals the earlier law. In this case, the Court found that
the Salary Standardization Law impliedly repealed any provisions of other laws that allowed for
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higher salaries for government officials. The Court also found that the requirement for written
concurrence from the COA for the engagement of private lawyers was a later law that repealed
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any earlier laws or regulations that did not require such concurrence.
Therefore, the Court concluded that the GM's actions were not in accordance with the law and
that the COA's decision to disallow the payments was correct.

MECANO V COA

The case involved Antonio Mecano, a government employee who was hospitalized for an illness
incurred in the performance of his duty. Mecano claimed reimbursement for his medical
expenses under Section 699 of the Revised Administrative Code (RAC). However, the
Commission on Audit (COA) denied his claim, arguing that Section 699 had been repealed by
the Administrative Code of 1987 (Admin. Code).

The Supreme Court ruled in favor of Mecano, finding that the Admin. Code did not repeal
Section 699 of the RAC. The Court applied the statutory construction principle that repeals of
statutes by implication are not favored. The Court found that there was no clear evidence that the
legislature intended to repeal Section 699 of the RAC when they enacted the Admin. Code.
Therefore, the Court concluded that Section 699 remained in effect.

PARAS V COMELEC

The case involved a petition to prevent a recall election of a barangay captain (village chief). The
petitioner argued that the recall election was barred by a provision in the Local Government
Code (LGC) that prohibits recall elections within one year of a regular local election.

The Supreme Court ruled that the prohibition did not apply to recall elections for barangay
captains. The Court applied the statutory construction principle that the Court should start with
the assumption that the legislature intended to enact an effective statute. The Court found that
interpreting the prohibition to apply to barangay captain recall elections would render the recall
provision ineffective, as barangay elections are not considered regular local elections.

Therefore, the Court concluded that the recall election was not barred by the LGC and could
proceed.

========================

The case involved a barangay captain (village chief) who was facing a recall election. The
captain argued that the recall election was illegal because it was held too soon after the previous
election. The Supreme Court ruled that the recall election was legal because the law that
prohibited recall elections did not apply to barangay captains.

Commissioner of Internal Revenue vs. ESSO Standard Eastern, Inc.

The case involved a dispute between the Commissioner of Internal Revenue and ESSO Standard
Eastern, Inc. over the refund of overpaid income tax. The Court of Tax Appeals ruled in favor of
ESSO, finding that the obligation to return the overpaid amount arose from the moment of
payment, regardless of when the tax credit was approved.

The Commissioner appealed the decision to the Supreme Court, arguing that income taxes are
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determined and paid on an annual basis and that a tax credit can only be considered once it has
been finally approved.
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The Supreme Court upheld the decision of the Court of Tax Appeals. The Court applied the
statutory construction principle that statutes should receive a sensible construction to avoid
unjust or absurd conclusions. The Court found that the Commissioner's interpretation of the law
would lead to an absurd result because it would require ESSO to pay taxes that it did not owe.

Therefore, the Court ruled that ESSO was entitled to a refund of the overpaid interest.

In a nutshell:

The case involved a dispute between the government and a company called ESSO
over taxes. ESSO overpaid its taxes and wanted a refund. The government said
that ESSO couldn't get a refund until the government approved it. The court
disagreed and said that ESSO was entitled to a refund because the government
had already received the overpayment.

URSUA V CA

The case involved a man named Cesario Ursua who used a fake name when visiting the Office of
the Ombudsman. Ursua was charged with violating a law that prohibits the use of aliases.

The Supreme Court ruled that Ursua DID NOT violate the law. The Court applied the
statutory construction principle that statutes should be construed in the light of their
purpose and intent.

The Court found that the law was intended to prohibit the use of aliases on a regular basis, not
just in a single instance. Therefore, the Court concluded that Ursua's use of a fake name on
one occasion did not violate the law.

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