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DIGESTED CASE: STAT CON CHAPTER 5 ARIS (Phil.) Inc., v. National Labor Relations Commission, et. al GR 90501 August 5, 1991 DOCTRINE: Laws are presumed constitutional. To justify nullification of a law, there must be a clear and unequivocal breach of the constitution, not a doubtful and argumentative implication; a law shall not be declared invalid unless the conflict with the constitution is clear beyond reasonable doubt. FACTS: April 11, 1988 - the employees of ARIS (Phil.) Inc. (private respondents) requested for a grievance conference for the failure of the management to attend to their complaints concerning their working surroundings. Unfortunately, the grievance conference was not arranged, thus, the employees resorted to conduct a rally and to protest the managements long silence and inaction to their complaints April 12, 1988 the management issued a memorandum to those employees who actively participated in the rally and required them to explain why they should not be terminated from the service of their conduct. Despite their explanation, the employees were still dismissed for violation of company rules and regulations. The dismissed employees filed a complaint for illegal dismissal against ARIS and Mr. Gavino Bayan with NLCR-NCR. June 22, 1989 Labor Arbiter Felipe Garduque III handed down a decision ordering ARIS to reinstate within 10 days from receipt of the decision the dismissed employees to their former respective positions or any substantial equivalent positions if already filled up, w/o loss of seniority right and privileges but with limited backwages of six months except complainant Leodegario de Guzman. July 19, 1989 the dismissed employees filed a Motion for Issuance of a Writ of Execution pursuant to Sec. 12 of RA 6715. For the succeeding days, the petitioner and private respondents filed an appeal and counter-appeal. August 29, 1989 ARIS filed an Opposition to the motion for execution CONTENTIONS: Petitioner: Sec.12 of RA 6715 on execution pending appeal cannot be applied retroactively on cases pending at the time of its effectivity because it does not expressly provide that it shall be given retroactive effect and to give retroactive effect to Sec. 12 thereof to pending cases would not only result in the imposition of additional obligation on petitioner but would also dilute its right to appeal since it would be burdened with the consequences of reinstatement w/o the benefit of a final judgment. Respondents (NLRC thru OSG): Sec. 12 of RA 6715 being merely procedural in nature, it can apply to cases pending at the time of its effectivity on the theory that no one can claim a vested right in a rule of procedure. Such a law is compatible with the constitutional provision on protection to labor. Petitioner: Sec. 12 of RA 6715 is violative of constitutional guaranty of due process it being oppressive and unreasonable. Respondents (NLRC thru OSG): The provision concerning the mandatory and automatic reinstatement of an employee whose dismissal is found unjustified by the labor arbiter is a valid exercise of the police power of the state and the contested provision is then a police legislation. ISSUE: Whether or not Sec. 12 of RA 6715 is unconstitutional. RULING: Sec. 12 of RA 6715 is not unconstitutional. The validity of the questioned law is not only supported and sustained by the foregoing consideration. As contended by the SG, it is a valid exercise of the police power of the State. Certainly, if the right of an employer to freely discharge his employees is subject to regulation by the State, basically in the exercise of its permanent police power on the theory that the preservation of the lives of the citizens is the basic duty of the State, that is more vital than the preservation of corporate profits. Then, by and pursuant to the same power, the State may authorize and immediate implementation, pending appeal, of a decision reinstating a dismissed or separated employee since that saving act is designed to stop, although temporarily since the appeal may be decided in favor of the appellant, a continuing threat of danger to the survival or even the life of the dismissed or separated employee and his family. * PETITION DISMISSED. __________________________ Lim vs. Pacquing [G.R. No. 115044. January 27, 1995] 16AUG Ponente: PADILLA, J. FACTS: The Charter of the City of Manila was enacted by Congress on 18 June 1949 (R.A. No. 409). On 1 January 1951, Executive Order No. 392 was issued transferring the authority to regulate jai-alais from local government to the Games and Amusements Board (GAB). On 07 September 1971, however, the Municipal Board of Manila nonetheless passed Ordinance No. 7065 entitled An Ordinance Authorizing the Mayor To Allow And Permit The Associated Development Corporation To Establish, Maintain And Operate A Jai-Alai In The City Of Manila, Under Certain Terms And Conditions And For Other Purposes. On 20 August 1975, Presidential Decree No. 771 was issued by then President Marcos. The decree, entitled Revoking All Powers and Authority of Local Government(s) To Grant Franchise, License or Permit And Regulate Wagers Or Betting By The Public On Horse And Dog Races, Jai-Alai Or Basque Pelota, And Other Forms Of Gambling, in Section 3 thereof, expressly revoked all existing franchises and permits issued by local governments.

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In May 1988, Associated Development Corporation (ADC) tried to operate a JaiAlai. The government through Games and Amusement Board intervened and invoked Presidential Decree No. 771 which expressly revoked all existing franchises and permits to operate all forms of gambling facilities (including JaiAlai) by local governments. ADC assails the constitutionality of P.D. No. 771. ISSUE: Whether or not P.D. No. 771 is violative of the equal protection and nonimpairment clauses of the Constitution. HELD: NO. P.D. No. 771 is valid and constitutional. RATIO: Presumption against unconstitutionality. There is nothing on record to show or even suggest that PD No. 771 has been repealed, altered or amended by any subsequent law or presidential issuance (when the executive still exercised legislative powers). Neither can it be tenably stated that the issue of the continued existence of ADCs franchise by reason of the unconstitutionality of PD No. 771 was settled in G.R. No. 115044, for the decision of the Courts First Division in said case, aside from not being final, cannot have the effect of nullifying PD No. 771 as unconstitutional, since only the Court En Banc has that power under Article VIII, Section 4(2) of the Constitution. And on the question of whether or not the government is estopped from contesting ADCs possession of a valid franchise, the well-settled rule is that the State cannot be put in estoppel by the mistakes or errors, if any, of its officials or agents. (Republic v. Intermediate Appellate Court, 209 SCRA 90) ____________________ Salvacion v. Central Bank of the Philippines 278 SCRA 27 FACTS: Greg Bartelli, an American tourist, was arrested for committing four counts of rape and serious illegal detention against Karen Salvacion. Police recovered from him several dollar checks and a dollar account in the China Banking Corp. He was, however, able to escape from prison. In a civil case filed against him, the trial court awarded Salvacion moral, exemplary and attorneys fees amounting to almost P1,000,000.00. Salvacion tried to execute the judgment on the dollar deposit of Bartelli with the China Banking Corp. but the latter refused arguing that Section 11 of Central Bank Circular No. 960 exempts foreign currency deposits from attachment, garnishment, or any other order or process of any court, legislative body, government agency or any administrative body whatsoever. Salvacion therefore filed this action for declaratory relief in the Supreme Court. ISSUE: Should Section 113 of Central Bank Circular No. 960 and Section 8 of Republic Act No. 6426, as amended by PD 1246, otherwise known as the Foreign Currency Deposit Act be made applicable to a foreign transient? HELD: The provisions of Section 113 of Central Bank Circular No. 960 and PD No. 1246, insofar as it amends Section 8 of Republic Act No. 6426, are hereby held to be INAPPLICABLE to this case because of its peculiar circumstances. Respondents are hereby required to comply with the writ of execution issued in the civil case and to release to petitioners the dollar deposit of Bartelli in such amount as would satisfy the judgment. RATIO: Supreme Court ruled that the questioned law makes futile the favorable judgment and award of damages that Salvacion and her parents fully deserve. It then proceeded to show that the economic basis for the enactment of RA No. 6426 is not anymore present; and even if it still exists, the questioned law still denies those entitled to due process of law for being unreasonable and oppressive. The intention of the law may be good when enacted. The law failed to anticipate the iniquitous effects producing outright injustice and inequality such as the case before us. The SC adopted the comment of the Solicitor General who argued that the Offshore Banking System and the Foreign Currency Deposit System were designed to draw deposits from foreign lenders and investors and, subsequently, to give the latter protection. However, the foreign currency deposit made by a transient or a tourist is not the kind of deposit encouraged by PD Nos. 1034 and 1035 and given incentives and protection by said laws because such depositor stays only for a few days in the country and, therefore, will maintain his deposit in the bank only for a short time. Considering that Bartelli is just a tourist or a transient, he is not entitled to the protection of Section 113 of Central Bank Circular No. 960 and PD No. 1246 against attachment, garnishment or other court processes. Further, the SC said: In fine, the application of the law depends on the extent of its justice. Eventually, if we rule that the questioned Section 113 of Central Bank Circular No. 960 which exempts from attachment, garnishment, or any other order or process of any court, legislative body, government agency or any administrative body whatsoever, is applicable to a foreign transient, injustice would result especially to a citizen aggrieved by a foreign guest like accused Greg Bartelli. This would negate Article 10 of the New Civil Code which provides that

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in case of doubt in the interpretation or application of laws, it is presumed that the lawmaking body intended right and justice to prevail. _______________ CARLOS ALONZO and CASIMIRA ALONZO, petitioners, vs. INTERMEDIATE APPELLATE COURT and TECLA PADUA, respondents. Perpetuo L.B. Alonzo for petitioners. Luis R. Reyes for private respondent. SYLLABUS 1 S. REMEDIAL LAW; STATUTORY CONSTRUCTION; INTERPRETED AND APPLIED IN CONSONANCE WITH JUSTICE. As has been STATUTES; aptly observed, we test a law by its results; and likewise, we may add, by its purposes. It is a cardinal rule that, in seeking the meaning of the law, the first concern of the judge should be to discover in its provisions the intent of the lawmaker. Unquestionably, the law should never be interpreted in such a way as to cause injustice as this is never within the legislative intent. An indispensable part of that intent, in fact, for we presume the good motives of the legislature, is to render justice. Thus, we interpret and apply the law not independently of but in consonance with justice. Law and justice are inseparable, and we must keep them so. To be sure, there are some laws that, while generally valid, may seem arbitrary when applied in a particular case because of its peculiar circumstances. In such a situation, we are not bound, because only of our nature and functions, to apply them just the same, in slavish obedience to their language. What we do instead is find a balance between the word and the will, that justice may be done even as the law is obeyed. Justice is always an essential ingredient of its decisions. Thus when the facts warrants, we interpret the law in a way that will render justice, presuming that it was the intention of the lawmaker, to begin with, that the law be dispensed with justice. So we have done in this case. 2. ID.; ID.; ID.; MUST BE READ ACCORDING TO ITS SPIRIT AND INTENT. While we admittedly may not legislate, we nevertheless have the power to interpret the law in such a way as to reflect the will of the legislature. While we may not read into the law a purpose that is not there, we nevertheless have the right to read out of it the reason for its enactment. In doing so, we defer not to "the letter that killeth" but to "the spirit that vivifieth," to give effect to the lawmaker's will. "The spirit, rather than the letter of a statute determines its construction, hence, a statute must be read according to its spirit or intent. For what is within the spirit is within the statute although it is not within the letter thereof, and that which is within the letter but not within the spirit is not within the statute. Stated differently, a thing which is within the intent of the lawmaker is as much within the statute as if within the letter; and a thing which is within the letter of the statute is not within the statute unless within the intent of the lawmakers." 3. CIVIL LAW; CONTRACTS; PACTO DE RETRO SALE; EXCEPTION TO GENERAL RULE ADOPTED IN CASE AT BAR. In arriving at our conclusion today, THE we are deviating from the strict letter of the law, which the respondent court understandably applied pursuant to existing jurisprudence. The said court acted properly as it had no competence to reverse the doctrines laid down by this Court in the abovecited cases. In fact, and this should be clearly stressed, we ourselves are not abandoning the De Conejero and Buttle doctrines. What we are doing simply is adopting an exception to the general rule, in view of the peculiar circumstances of this case. The co-heirs in this case were undeniably informed of the sales although no notice in writing was given them. And there is no doubt either that the 30-day period began and ended during the 14 years between the sales in question and the filing of the complaint for redemption in 1977, without the co-heirs exercising their right of redemption. These are the justifications for this exception. DECISIO C NRUZ, J p: The question is sometimes asked, in serious inquiry or in curious conjecture, whether we are a court of law or a court of justice. Do we apply the law even if it is unjust or do we administer justice even against the law? Thus queried, we do not equivocate. The answer is that we do neither because we are a court both of law and of justice. We apply the law with justice for that is our mission and purpose in the scheme of our Republic. This case is an illustration. Five brothers and sisters inherited in equal pro indiviso shares a parcel of land registered in the mane of their deceased parents under OCT No. 10977 of the Registry of Deeds of Tarlac. 1 On March 15, 1963, one of them, Celestino Padua, transferred his undivided share of the herein petitioners for the sum of P550.00 by way of absolute sale. 2 One year later, on April 22, 1964, Eustaquia Padua, his sister, sold her own share to the same vendees, in an instrument denominated "Con Pacto de Retro Sale," for the sum of P440.00. 3 By virtue of such agreements, the petitioners occupied, after the said sales, an area corresponding to two-fifths of the said lot, representing the portions sold to them. The vendees subsequently enclosed the same with a fence. In 1975, with their consent, their son Eduardo Alonzo and his wife built a semi-concrete house on a part of the enclosed area. 4 On February 25, 1976, Mariano Padua, one of the five co-heirs, sought to redeem the area sold to the spouses Alonzo, but his complaint was dismissed when it appeared that he was an American citizen. 5 On May 27, 1977, however, Tecla Padua, another co-heir, filed her own complaint invoking the same right of redemption claimed by her brother. 6 The trial court * also dismisses this complaint, now on the ground that the right had lapsed, not having been exercised within thirty days from notice of the sales in 1963 and 1964. Although there was no written notice, it was held that actual knowledge of the sales by the co-heirs satisfied the requirement of the law. 7 In truth, such actual notice as acquired by the co-heirs cannot be plausibly denied. The other co-heirs, including Tecla Padua, lived on the same lot, which consisted of only 604 square meters, including the portions sold to the petitioners. 8 Eustaquia herself, who had sold her portion, was staying in the same house with her sister Tecla, who later claimed redemption. 9 Moreover, the

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petitioners and the private respondents were close friends and neighbors whose children went to school together. 10 It is highly improbable that the other coheirs were unaware of the sales and that they thought, as they alleged, that the area occupied by the petitioners had merely been mortgaged by Celestino and Eustaquia. In the circumstances just narrated, it was impossible for Tecla not to know that the area occupied by the petitioners had been purchased by them from the other co-heirs. Especially significant was the erection thereon of the permanent semi-concrete structure by the petitioners' son, which was done without objection on her part or of any of the other co-heirs. The only real question in this case, therefore, is the correct interpretation and application of the pertinent law as invoked, interestingly enough, by both the petitioners and the private respondents. This is Article 1088 of the Civil Code, providing as follows: "Art. 1088. Should any of the heirs sell his hereditary rights to a stranger before the partition, any or all of the co-heirs may be subrogated to the rights of the purchaser by reimbursing him for the price of the sale, provided they do so within the period of one month from the time they were notified in writing of the sale by the vendor." In reversing the trial court, the respondent court ** declared that the notice required by the said article was written notice and that actual notice would not suffice as a substitute. Citing the same case of De Conejero v. Court of Appeals 11 applied by the trial court, the respondent court held that that decision, interpreting a like rule in Article 1623, stressed the need for written notice although no particular form was required. Thus, according to Justice J.B.L. Reyes, who was the ponente of the Court, furnishing the co-heirs with a copy of the deed of sale of the property subject to redemption would satisfy the requirement for written notice. "So long, therefore, as the latter (i.e., the redemptioner) is informed in writing of the sale and the particulars thereof," he declared, "the thirty days for redemption start running." In the earlier decision of Butte v. Uy, 12 the Court, speaking through the same learned jurist, emphasized that the written notice should be given by the vendor and not the vendees, conformably to a similar requirement under Article 1623, reading as follows: "Art. 1623. The right of legal predemption or redemption shall not be exercised except within thirty days from the notice in writing by the prospective vendor, or by the vendors, as the case may be. The deed of sale shall not be recorded in the Registry of Property, unless accompanied by an affidavit of the vendor that he has given written notice thereof to all possible redemptioners. "The right of redemption of co-owners excludes that of the adjoining owners." As "it is thus apparent that the Philippine legislature in Article 1623 deliberately selected a particular method of giving notice, and that notice must be deemed exclusive," the Court held that notice given by the vendees and not the vendor would not toll the running of the 30-day period. Cdpr The petition before us appears to be an illustration of the Holmes dictum that "hard cases make bad laws" as the petitioners obviously cannot argue against the fact that there was really no written notice given by the vendors to their co-heirs. Strictly applied and interpreted, Article 1088 can lead to only one conclusion, to wit, that in view of such deficiency, the 30-day period for redemption had not begun to run, much less expired in 1977. But as has also been aptly observed, we test a law by its results; and likewise, we may add, by its purposes. It is a cardinal rule that, in seeking the meaning of the law, the first concern of the judge should be to discover in its provisions the intent of the lawmaker. Unquestionably, the law should never be interpreted in such a way as to cause injustice as this is never within the legislative intent. An indispensable part of that intent, in fact, for we presume the good motives of the legislature, is to render justice. Thus, we interpret and apply the law not independently of but in consonance with justice. Law and justice are inseparable, and we must keep them so. To be sure, there are some laws that, while generally valid, may seem arbitrary when applied in a particular case because of its peculiar circumstances. In such a situation, we are not bound, because only of our nature and functions, to apply them just the same, in slavish obedience to their language. What we do instead is find a balance between the word and the will, that justice may be done even as the law is obeyed. ______________ Alonzo v. Intermediate Appellate Court Case No. 11 G.R. No. L-72873 (May 28, 1987) Chapter III, Page 89, Footnote No.54 FACTS: Five siblings inherited in equal pro indiviso shares a parcel of land registered in the name of their deceased parents. Two siblings sold their share to the same vendee. By virtue of such agreements, the Petitioners occupied after the said sales, 2/5 of the lot, representing the portions bought. They subsequently enclosed their portion with a fence and built a semi-concrete house. One of the sisters filed a complaint invoking the right to redeem the area sold. The trial court dismissed this complaint because the time had lapsed, not having been exercised within 30 days from notice of the sales. ISSUE: 1. W/N there was a valid notice. 2. W/N Art. 1088 of the Civil Code was interpreted correctly. HELD: Although there was no written notice, there was actual knowledge of the sales satisfying the requirement of the law. It is unbelievable that the co-heirs were unaware of the sale, with the erection of a permanent semi-concrete structure. While Art. 1088 of the Civil Code stresses the need for a written notice of sale; the Petitioners claimed that because there was no written notice, despite their obvious knowledge of it, the 30-day period for redemption had not yet begun. The intent of the lawmakers was to ensure that the redemptioner

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was properly notified of the sale and to indicate the date of such notice as the starting time of the 30-day period of redemption. The co-heirs in this case were undeniably informed of the sales although no notice in writing was given to them. LATIN MAXIM: 1, 8, 9a, 10, 11d, 11e, 12a, 17 _________________________ Berces, Jr. vs. Hon. Guingona, Jr. FACTS: Petitioner filed two administrative cases against Mayor Corral with the Sangguniang Panlalawigan (SP) for abuse of authority and/or oppression and dishonesty. SP ruled in favor of the petitioner and ordered the suspension of Corral. The latter appealed the decision to the Office of the President (OP) under Section 67 (b) of the Local Government Code and prayed to stay execution. OP granted the petition of Corral. Petitioners motion for reconsideration was denied; hence, this petition for certiorari and prohibition. ISSUE/S: W/N Section 68 of RA 7160 impliedly repealed Section 6 of AO 118. RULING: The court denied the instant petition and upheld that Section 68 of RA7160 did not impliedly repealed Section 6 of AO 118; thus, must be construed in harmony with each other. Section 68 of RA 7160 provides: An appeal shall not prevent a decision from becoming final and executory. While, Section 6 of AO 118 provides: Office of the President may direct or stay the execution of the decision/resolution/order appealed from The court held that absence of express repeal, a subsequent law cannot be construed as repealing a prior law unless an irreconcilable inconsistency and repugnancy exists in terms of the new and old. The two laws must be absolutely incompatible that they cannot be made to stand together. In the case at bar, the court finds the two laws not irreconcilably inconsistent and repugnant; thus, the two laws must in be read together. Section 68 of RA 7160 must be construed as giving discretion to the reviewing officials to stay the execution of the appealed decision. There is nothing to infer therefrom that the reviewing officials are deprived of the authority to order a stay of the appealed order. _______________ Mecano vs. Commission on Audit (COA) FACTS: Mecano seeks to nullify the decision of COA denying his claim for reimbursement. He was a Director II of the National Bureau of Investigation (NBI) who was hospitalized for Cholecystitis on account which he incurred medical and hospitalization expenses. COA Chairman Domingo denied petitioners claim on the ground hat Section 699 of the Revised Administrative Code (RAC) has been repealed by the Administrative Code (AC) of 1987 since the same section was not restated nor re-enacted in the said code. ISSUE/S: W/N enactment of the AC of 1987 operates to repeal RAC of 1917. RULING: The court granted the instant petition, ordered COA to give due course to petitioners claim and benefits, and held that AC of 1987 did not operate to repeal RAC of 1917. The repealing clause of AC 1987 falls under the category of an implied repeal. Comparing the two Codes, it shows that the New Code does not cover nor attempt to cover the entire subject matter of the Old Code. Repeals of Statutes by implication are not favored. It is presumed that Legislature, in passing a statute, did not intend to interfere or abrogate any former law relating to some matter; unless, the repugnancy between the two is clear and convincing, and flowing necessary from the language used. Otherwise, effort must be used to make all acts stand, and if possible be reconciled. Presumption against effectiveness It is presumed that Legislature intends to enact meanings that will render laws operative and effective, and to prevent persons from eluding them. In case of doubt, construction will be favored toward the effectiveness of laws. __________________

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Antonio Mecano vs. Commission on Audit GR No. 103982 December 11, 1992 Facts: Petitioner Antonio Mecano, a Director II of the National Bureau of Investigation, filed a petition for certoriari to nullify the decision of Commission of Audit (COA) in the 7th Indorsement denying him of reimbursement anchored on the provisions of Section 699 of the Revised Administrative Code (RAC) in the amount of Php 40,831.00. Earlier, the petitioner was hospitalized because of cholecystitis and incurred the abovementioned amount. Under Sec. 699 of RAC, he is entitled to allowances in case of injury, sickness, death incurred in the performance of duty. Hence, the petitioner requested reimbursement for his expenses to NBI Director Alfredo Lim forwarding the request to the Secretary of Justice. The request was returned due to the comments of the COA Chairman stating that the RAC being relied upon was already repealed by the Administrative Code of 1987. The petitioner resubmitted the request asserting that the Administrative Code did not operate to repeal or abrogate in its entirety the RAC, including Section 699. Director Lim transmitted the request to the Justice Secretary who recommended the payment to the COA Chairman. The COA Chairman again denied the request asserting the same reason and furthered that Section 699 was not restated nor re-enacted in the Administrative Code of 1987. According to the COA Chairman, the claim may be filed with the Employees' Compensation Commission, considering that the illness of Director Mecano occurred after the effectivity of the Administrative Code of 1987. Eventually, the request was again returned to Director Lim with an advice of elevating the matter in the Supreme Court if he so desires. Issue: Whether or not the Administrative Code of 1987 repealed or abrogated the Revised Administrative Code including Section 699 Decision: In determining whether a particular law has been repealed or not by a subsequent law is a matter of legislative intent which is manifested in the incorporation of a repealing provision which expressly and specifically cites the particular law or laws, and portions that are intended to be repealed. Scrutinizing the repealing clause will determine if the new law really supplants the old law. The repealing clause of the Administrative Code of 1987 states: Sec. 27. Repealing Clause. All laws, decrees, orders, rules and regulations, or portions thereof, inconsistent with this Code are hereby repealed or modified accordingly. The repealing clause of the Administrative Code of 1987 is repeal by implication because it failed to identify which specific laws shall be repealed. The failure to indicate specific laws reveal that the intent was not to repeal any existing law, unless an irreconcilable inconsistency and repugnancy exist in the terms of the new and old laws. The two categories of repeal by implication are as follows: a) where provisions in the two acts on the same subject matter are in an irreconcilable conflict, the later act to the extent of the conflict constitutes an implied repeal of the earlier one; and b) if the later act covers the whole subject of the earlier one and is clearly intended as a substitute, it will operate to repeal the earlier law. In this case, the new Code (Administrative Code of 1987) does not cover nor attempt to cover the entirety of the old codes (Sec 699, RAC) subject matter. There are matters included in the old Code which are not found in the new one, like the provisions on notaries public, the leave law, the public bonding law, military reservations, claims for sickness benefits under Section 699, and others. Apparently, COA failed to prove that RAC has conflicting provisions with the Administrative Code of 1987 that may warrant the formers repeal. The rules of statutory construction state that repeal of statutes by implication are not favored. The presumption is against inconsistency and repugnancy for the legislature is presumed to know the existing laws on the subject and not to have enacted inconsistent or conflicting statutes. The Court explained that it is presumed that laws are passed with full knowledge of existing laws related to the matter. In passing a statute, it is reasonable to presume that it does not intend to interfere with or abrogate with previously passed laws, unless there are irreconcilable and conflicting provisions between them. Hence, every effort must be exhausted to make all acts stand and if possible, reconciled; the later act will not operate as a repeal of the earlier. Wherefore, the Court granted the petition and ordered the respondent to reimburse the petitioners claim for benefits.