National tobacco v comm on audit

Facts: NTA is a govt owned and controlled corp tasked to supervise and
improve the viability of the tobacco industry in this country. Congress
passed RA !"# $an act prescribing a revised compensation and position
classification in the govt and for other purposes$. %ursuant to sec &'
of said law( the dbm issued corporate compensation circular to serve as
the implementing rules and regulations of RA !#". %rior to its
effectivity( the officials and employees of NTA have been en)oying mid*
yr amelioration benefit. +aid benefit was changed to educational
assistance. ,owever( resident auditor of NTA issued a notice of
disallowance of the payment of such benefit stating that NTA has no
statutory authority to grant the incentive and this was further
complied. %etitioners appealed to C-A praying for the lifting of the
disallowance. that since they have been receiving the social
amelioration or educational assistance benefit before /uly 0( 01"1( when
RA !"# took effect( and the benefit was not integrated into their
standardi2ed salary rate( they are entitled to receive it even after the
effectivity of such act. %etitioners also invoked second par of sec 0&
$such other addtl compensation( whether in cash or in kind( being
received by incumbents only as of /uly 01"1 not integrated into the
standardi2ed salary rates shall continue to be authori2ed$. -n the
other hand( C-A stressed the provision of RA !"# $payment of other
allowances or fringe benefits 333 not mentioned in sub par #.4 and #.#
above shall be discontinued effective nov 01"4. %ayment made for such
allowance or fringe benefits after said date shall be considered as
illegal disbursement of funds$. Furthermore( such benefit is not among
those mentioned in said paragraphs.
5ssue: won benefit given to the individual petitioners prior to
enactment of said law in authori2ed under the law
,eld:
5t is indeed decisively clear that the benefits mentioned in the first
sentence of +ection 0& and sub*paragraphs #.4 and #.# of CCC No. 06 are
entirely different from the benefit in dispute( denominated as
7ducational Assistance. The non*inclusion by the 8epartment of 9udget
and :anagement of the controverted educational assistance in +ub*
paragraphs #.4 and #.# of CCC No. 06 is e3pected since the term
allowance does not include the ;uestioned benefit which belongs to a
different genus.
Cardinal is the rule in statutory construction <that the particular
words( clauses and phrases should not be studied as detached and
isolated e3pressions( but the whole and every part of the statute must
be considered in fi3ing the meaning of any of its parts and in order to
produce a harmonious whole. A statute must so construed as to harmoni2e
and give effect to all its provisions whenever possible.=
And the rule * that statute must be construed as a whole * re;uires that
apparently conflicting provisions should be reconciled and harmoni2ed(
if at all possible. 5t is likewise a basic precept in statutory
construction that the intent of the legislature is the controlling
factor in the interpretation of the sub)ect statute.
As mandated by the second sentence of +ection 0&( in relation to +ection
0! of the Republic Act under interpretation( the mid*year educational
assistance should continue to be authori2ed.
Co v Civil Register of :anila
Facts: in the birth cert of the petitioners( it is stated that their
parents are Chinese citi2ens. Their father filed an application for his
naturali2ation as a citi2en of the %hilippines under >-5 no &!6 and his
app was granted under %8 06##. %etitioners alleged in their petition
that:
0? they were born in the phil and legitimate children of Co 9oon %eng
@petitioners father?
&? co boon %eng is a former Chinese citi2en but was naturali2ed as
Filipino citi2en
'? at the time of their birth( their father was still a Chinese citi2en
thatAs why entry in their birth cert as to their father citi2enship was
Chinese
4? upon granting of phil citi2enship by naturali2ation to their father(
petitioners who were born in the phil and still minors at that time
became Filipino citi2ens thru the derivative mode of naturali2ation. As
stated in naturali2ation law @commonwealth act 4!'? $minor children of
persons naturali2ed under this law who have been born in the phil shall
be considered citi2ens thereof$
#? the naturali2ation of petitionersA father was an act affecting their
civil status that must be recorded in the civil register. The provision
in the new civil code provides that $acts( events and )udicial decrees
concerning the civil status of persons shall be recorded in the civil
register$
%etitioners prayed that the trial court render )udgment correcting and
changing the entries in their birth cert as to the citi2enship of their
father( from Chinese to Filipino. Court dismissed the case. %etitioners
filed a reconsideration with the rtc but it was also denied.
,eld: sol gen contends that the court did not err in issuing the
assailed orders bec >-5 &!6 @deals with the re;uirements and procedure
for naturali2ation by presidential decree? and CA 4!' @deals with the
re;uirements and procedure for naturali2ation by )udicial decree? are
separate and distinct laws. therefore( not in pari materia. Furthermore(
they cannot invoke art 46! of the NCC and rule 06" of rules of court
because it must be one that reflects a fact e3isting or at the time of
birth. :oreover( >-5 &!6( the naturali2ation of their father did not
render them also naturali2ed.
The rule on statutory construction provides that:
+tatutes in pari materia should be read and construed together because
enactments of the same legislature on the same sub)ect are supposed to
form part of one uniform system. later statutes are supplementary or
complimentary to the earlier enactments and in the passage of its acts
the legislature is supposed to have in mind the e3isting legislations on
the sub)ect and to have enacted its new act with reference thereto.
+tatutes in pari materia should be construed together to attain the
purpose of an e3pressed national policy( thus:
-n the presumption that whenever the legislature enacts a provision it
has in mind the previous statutes relating to the same sub)ect matter(
it is held that in the absence of any e3press repeal or amendment
therein( the new provision was enacted in accord with the legislative
policy embodied in those prior statutes( and they all should be
construed together. %rovisions in an act which are omitted in another
act relating to the same sub)ect matter will be applied in a proceeding
under the other act( when not inconsistent with its purpose. %rior
statutes relating to the same sub)ect matter are to be compared with the
new provisions. and if possible by reasonable construction( both are to
be construed that effect is given to every provision of each. +tatutes
in pari materia( although in apparent conflict( are so far as reasonably
possible construed to be in harmony with each other.