CHAPTER XII RECENT CASES ON STATUTORY CONSTRUCTION The term may is indicative of a mere possibility, an opportunity or an option.

tion. An implied repeal is predicated on a substantial conflict between the new and prior laws. The abrogation or repeal of a law cannot be assumed; the intention to revoke must be clear and manifest. When the law speaks in clear and categorical language, there is no occasion for interpretation. Penal laws must be construed strictly. Such rule is founded on the tenderness of the law for the rights of individuals and on the plain principle that the power of punishment is vested in the Congress, not in the Judicial department. Where a requirement is made explicit and unambiguous terms, no discretion is left to the judiciary. It must see to it that the mandate is obeyed. Statutes that are remedial, or that do not create new or take away vested rights, do not fall