People v. Buenviaje, G.R. No.

L-22945, March 3, 1925 (GUIANG)

Doctrine: Definition sections and interpretation clauses
Jovita Buenviaje is accused of violating the Medical Act when she, without having obtained from
the Board of Medical Examiners the corresponding certificate of registration for the practice of
medicine in the Philippine Islands, practiced medicine in the City of Manila. She treated the head
and body of Regino Noble (Payment for her services: PISO! Lol) for the purpose of curing him of
illnesses from which he pretended to suffer. She also advertised and offered her services as a
physician through cards and newspapers.
She demurred in the court on the grounds: (1) That the information stated more than one offense,
and (2) that it was not drawn in accordance with the form prescribed by law.
Demurrer was overruled. Buenviaje pleaded not guilty so the trial ensued. She admitted the
allegations against her but she adduced that she advertised herself as a doctor of chiropractic
and she graduated as a doctor in chiropractic in the American University School of Chiropractic
of Chicago.
The trial court found her guilty and, in accordance with section 2678 of the Administrative Code,
sentenced her to pay a fine of P300.
Thus, this appeal to the SC. One of the assignment of errors was that chiropractic has nothing to
do with medicine and that the practice of that profession can therefore not be regarded as practice
of medicine. (parang sinasabi niya na she should not be subjected to the Medical Act.)

ISSUE: WON chiropractic falls under the term practice of medicine? YES.

RULING: Assuming without conceding that chiropractic does not fall within the term "practice of
medicine" in its ordinary acceptation, we have the statutory definition contained in section 770 of the
Administrative Code and which clearly includes the manipulations employed in chiropractic. The
statutory definition necessarily prevails over the ordinary one.

Buenviaje also contends that the prohibition in section 783 against the unauthorized use of the title
"doctor" must be understood to refer to "Doctor of Medicine" and has no application to doctors of
chiropractic. Under different circumstances that might possibly be so, but where, as here, chiropractic is
by statute made a form of the practice of medicine, it necessarily follows that a person holding himself
out as a doctor of chiropractic in legal effect represents himself as a doctor of medicine.

Statutory Definition
- The legislative definition controls the meaning of a statutory word, irrespective of any other meaning the
word or phrase may have in its ordinary or usual sense.
- For the legislature, in adopting a specific definition is deemed to have restricted the meaning of the word
within the terms of the definition.
- When the legislature defines a word, it does not usurp the courts function to interpret the laws but it
merely legislates what should form part of the law itself.
- While the definition of terms in a statute must be given all the weight due to them in the construction of
the provision in which they are used, the terms or phrases being part and parcel of the whole statute must
be given effect in their entirety as a harmonious, coordinated and integrated unit, not as a mass of
heterogeneous and unrelated if not incongruous terms, clauses and sentences.
Qualification of rule
- The statutory definition of a word or term as used in this Act is controlling only in so far as said act is
concerned.
- The general rule that the statutory definitions control the meaning of statutory words does not apply
where its application creates obvious incongruities in the language of the statute, destroys one of its major
purposes, or becomes illogical as a result of a change in its factual basis.
- However, in a subsequent case, it was held that of a statute remains unchanged, it must be interpreted
according to its clear, original mandate until the legislature amends it. (from Agpalo)

Magtajas & City of Cagayan de Oro v Pryce Properties Corp & PAGCOR, G.R. No. 111097, July
20, 1994 (GUIANG)
Doctrine: Construction of statute as a whole

PAGCOR was expanding its operations and decided to open a casino in Cagayan de Oro City (CDO).
They leased and renovated a portion of a building owned by Pryce Corporation for the said project.
The project was denounced by religious, women's, and youth groups as well as the local politicians of
CDO. In December 1992, the Sangguniang Panlungsod of CDO enacted Ordinance No. 3353, prohibiting
and/or cancelling business permits to establishments used for the operation of casinos and providing
corresponding penalties. Later on, they enacted a stricter ordinance, Ordinance 3375-93 which prohibits
the operation of gambling casino and providing penalties for the violation thereof. Pryce Corporation
assailed the validity of the ordinances before the Court of Appeals. GRANTED.
Thus this petition by Mayor Magtajas and the local government of CDO, seeking the SC to declare that
CA erred in holding that the Sangguniang Panlungsod of DDO does not have the power and authority to
prohibit the establishment and operation of a PAGCOR gambling casino within the City's territorial
limits, as stated in RA 7610 (LGC).
The petitioners aver that, under the "General Welfare" clause of the LGC, political subdivisions like
CDO is empowered to enact ordinances for the purposes of preventing, suppressing and imposing
appropriate penalties for gambling and other prohibited games of chance and such other activities inimical
to the welfare and morals of the inhabitants of the city. They are claiming that the LGC repealed PD
1869, which created the PAGCOR.

ISSUE: WON the LGC repealed PD 1869 (in the sense that the LGC conferred with the LGUs the power
to regulate the casinos without contravening any law such as the PD 1869) NO!

RULING: The petitioners only invoked Par. (f) of the repealing clause (the general repealing clause),
conveniently discarding the rest of the provision which mentions the specific laws or the parts thereof
which are repealed or modified by the LGC. Significantly, P.D. 1869 is not one of these explicitly
repealed laws. Moreover, there is no sufficient indication of an implied repeal of P.D. 1869. On the
contrary, PAGCOR is mentioned as the source of funding in two later enactments of Congress, which
shows that the PAGCOR charter (PD 1869) has not been repealed by the Local Government Code but has
in fact been improved as it were to make the entity more responsive to the fiscal problems of the
government.

DOCTRINE: Generally, a statute is passed as a whole and not in parts or sections and is animated by one
general purpose and intent. Consequently, each part or section should be construed in connection with
every other part and section so as to produce a harmonious whole.

The intent or meaning of a statue should be ascertained from the statute taken as a whole and not from an
isolated part or provision thereof. The legislative meaning is to be extracted form the statue as a whole. Its
clauses are not to be segrated, but every part of a statute is to be construed with reference to every other
part and every word and phrase in connection with its context. Optima statute interpretatrix est ipsum
statutum. The best interpreter of a statute is the statue itself. (from Agpalo)

Abbas Kidda v. Comelec, G.R. No. 196271, October 18, 2011 (GUIANG)
Doctrine: Presumption of constitutionality
The State, through Sections 15 to 22, Article X of the 1987 Constitution, mandated the creation of
autonomous regions in Muslim Mindanao and the Cordilleras. In November 6, 1990, the
Autonomous Region of Muslim Mindanao (ARMM) was established.
There were then various Republic Acts that were created with regards to the elections of
Mindanao. The first was regarding the setting of the first regular elections, but various RAs were
created after it, which postponed the election and changed its date:

RA 6734: organic act that established the ARMM and scheduled the first regular elections for the
ARMM regional officials.
RA 9054: amended the ARMM Charter and reset the regular elections for the ARMM regional
officials to the second Monday of September 2001.
RA 9140: further reset the first regular elections to November 26, 2001.
RA 9333: reset for the third time the ARMM regional elections to the 2nd Monday of August
2005 and on the same date every 3 years thereafter. Pursuant to RA No. 9333, the next ARMM
regional elections should have been held on August 8, 2011. COMELEC had begun preparations
for these elections and had accepted certificates of candidacies for the various regional offices to
be elected.
RA 10153: But on June 30, 2011, RA No. 10153 was enacted, resetting the next ARMM regular
elections to May 2013 to coincide with the regular national and local elections of the country.
The constitutionality of RA 10153 is now being assailed on the ground that there was a violation
of the autonomy granted to ARMM, the appointment of OICs by the President was
unconstitutional, and the manner of passing the bill was flawed.

Issue: WON RA 10153 is unconstitutional No.

Ruling: On the general claim that RA No. 10153 is unconstitutional, the Court reiterated the established
rule that every statute is presumed valid. Congress has in its favor the presumption of constitutionality of
its acts, and the party challenging the validity of a statute has the onerous task of rebutting this
presumption. Any reasonable doubt about the validity of the law should be resolved in favor of its
constitutionality. To doubt is to sustain. This presumption is based on the doctrine of separation of
powers which enjoins upon each department a becoming respect for the acts of the other
departments. The theory is that as the joint act of Congress and the President of the Philippines, a law has
been carefully studied and determined to be in accordance with the fundamental law before it was finally
enacted.

In the case at bar, Congress acted within its powers and pursuant to a constitutional mandate the
synchronization of national and local elections when it enacted RA No. 10153. Given an array of
choices, it acted within due constitutional bounds and with marked reasonableness in light of the
necessary adjustments that synchronization demands.

On the specific grounds:
1. Violation of the autonomy of ARMM
- RA 10153 does not amend what the organic law of the ARMM sets outs in terms of structure
of governance and, thus, does not violate the autonomy granted to ARMM. What RA No.
10153 only does is to appoint officers-in-charge for the Office of the Regional Governor,
Regional Vice Governor and Members of the Regional Legislative Assembly who shall
perform the functions pertaining to the said offices until the officials duly elected in the May
2013 elections shall have qualified and assumed office. This power is different from
appointing elective ARMM officials for the shortened term which will end on the assumption
to office of the officials elected in the May 2013 elections. This is the better option because th
holdover provision in RA 9054 is actually the one that is unconstitutional (You cannot
shorten or lengthen the term of an elective official.)
2. Violation of Article VI, 26(2), which provides that before bills passed by either the House or the
Senate can become laws, they must pass through three readings on separate days. There was a
contention that no necessity existed for the immediate enactment of these bills since there was no
public calamity or emergency that had to be met
- The court cannot review the factual basis of the presidential certification, pursuant to the
observance of the doctrine of separation of powers.