COMPILATION OF CASE DIGEST IN

STATUTORY CONSTRUCTION
(BASIC GUIDELINES IN STATCON)

Timan, Mera Lyka A. July 19, 2018

1st yr. Block 2 – JD Atty. Relson P. Moral

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LEGISLATIVE INTENT
Ramirez vs. Court of Appeals
Chavez vs. Judicial and Bar Council
Mecano vs. COA
Airspona vs. CA
Chinabank vs. Ortega

VERBA LEGIS
Padilla et. al. vs. Congress
Saguisag et. al. vs. Ochoa
Globe Mackay Cable and Radio
Communications vs. NLRC
Basbacio vs. Secretary of Justice
Bolos vs. Bolos

STATUTE AS A WHOLE
Commissioner of Customs vs. Esso
Standard Eastern Inc.
JMM Promotions and Mgt. Inc. vs. NLRC
Leynes vs. COA
Radio Toshiba Phils. vs. IAC

SPIRIT AND PURPOSE OF THE LAW

De Guia vs. COMELEC
Salenillas vs. CA
Commendador, et. al. De Villa, et. al.
Rufino Lopez & Sons, Inc. vs. CTA
Alonzo vs. IAC

DOCTRINE OF NECESSARY IMPLICATION

Chua vs. CSC
City of Manila vs. Gomez

CASUS OMISSUS
Chavez vs. JBC
Sps. Delfino vs. St. James Hospital
People vs. Manantan

STARE DECISIS
Lazatin vs. Ombudsman
Phil. Carpet Manufacturing Corp. et. al vs. Tagyamon
Cabaobas et. al vs. Pepsi-Cola Products, Phils., Inc.

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G.R. No. 93833 September 28, 1995
SOCCORO D. RAMIREZ, petitioner.
vs.
HONORABLE COURT OF APPEALS, and ESTER S. GARCIA, respondents.

FACTS:

 A civil case damages was filed by petitioner Ramirez in the RTC of QC alleging that the private
respondent, Garcia, in a confrontation in the latter’s office, allegedly vexed, insulted and humiliated her
in a hostile and furious mood and in manner offensive to petitioner’s dignity and personality, contrary
to morals, good customs and public policy.
 In support of her claim, petitioner produced a verbatim transcript of the event and sought moral
damages, attorney’s fees and other expenses of litigation.
 As a result of petitioner’s recording of the event and alleging that the said act of secretly taping the
confrontation was illegal, private respondent filed a criminal case before the RTC of Pasay City for
violation of RA 4200, entitled “An Act to Prohibit and Penalize Wire Tapping and other Related Violations
of Private Communication, and other purposes”.
 The petitioner filed a Motion to Quash the Information on the ground that the facts charged do not
constitute an offense in violation of RA 4200 and that violation punished by the said act refers to the
taping of a communication by a person other than a participant in a communication.
 The Trial Court granted the Motion to Quash. From the said order, the private respondent filed a Petition
for Review on Certiorari in the SC, which forthwith referred the case to the CA in a resolution.
 The CA promulgated its decision which declared the trial court’s order null and void. Consequently,
petitioner filed a Motion for Reconsideration which was likewise denied by the CA.

ISSUES:

 Whether or not the applicable provision of RA 4200 does not apply to the taping of a private conversation
by one of the parties to the conversation.
 W/O RA 4200 penalizes the taping of a “private communication” not a “private conversation”.
HELD:

 No. Legislative intent is determined principally from the language of a statute. Where the language of
the statute is clear and unambiguous, the law is applied according to its express terms, and
interpretation would be resorted to only where a literal interpretation would be either impossible. The
provision seeks to penalize even those privy to the private communications. Where the law makes no
distinction, one does not distinguish.
 Yes. The contention that private communication in Sec. 1 of R.A 4200 does not include private
conversations narrows the ordinary meaning of the word communication to a point of absurdity. Any
doubts about the legislative body’s meaning of these phrases are put to rest by the fact that the terms
“conversation” and “communication” were interchangeably used during the explanatory note to the bill.

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G.R. No. 202242 July 17, 2012
FRANCISCO I. CHAVEZ, Petitioner.
vs.
JUDICIAL AND BAR COUNCIL, ET. AL, Respondents.

FACTS:

 Both Malolos and 1935 Constitution had vested the power to appoint the members of the Judiciary in
the President, subject to confirmation by the Commission on Appointments.
 Then, with the fusion of executive and legislative power under the 1973 Constitution, the appointment
of judges and justices was no longer subject to the scrutiny of another body, it was absolute, except that
the appointees must have all the qualifications and none of the disqualifications.
 Prompted by the clamor to rid the process of appointments to the Judiciary from political pressure and
partisan activities, the members of the Constitutional Commission saw the need to create a separate,
competent, and independent body to recommend nominees to the President. Thus, it conceived of a
body representative of all the stake holders in the judicial appointment process and called it the Judicial
and Bar Council (JBC).
 Its composition, term and functions are provided under Section 8, Article VIII of the 1987 Constitution.
 Section 8. (1) A Judicial and Bar Council is hereby created under the supervision of the Supreme Court
composed of the Chief Justice as ex officio Chairman, the Secretary of Justice, and a representative of
the Congress as ex officio Members, a representative of the Integrated Bar, a professor of law, a retired
Member of the Supreme Court, and a representative of the private sector.
 In compliance therewith, Congress, from the moment of the creation of the JBC, designated one
representative to sit in the JBC to act as one of the ex officio members.
 In 1994, the composition of JBC was substantially altered. Instead of having only 7 members, and 8 th
member was added to the JBC as 2 representatives from Congress. One from House of Representatives
and one from the Senate which each having a ½ vote. Then curiously, the JBC En Banc decided to allow
each representative from Congress to cast one full vote.

ISSUE:

 Whether or not the first paragraph of Section 8, Article VIII of the 1987 Constitution allow more than
one member of the Congress to sit in the JBC.

HELD:

 No. From a simple reading of the Section 8 (1), Article VIII of the Constitution, it can readily be discerned
that the provision is clear and unambiguous. The use of the singular “a” preceding “representative of
Congress” is unequivocal and leaves no room for any other construction. It is indicative of what the
members of the Constitutional Commission had in mind, that is, Congress may designated only one
representative to the JBC. One of the primary and basic rules in Statutory Construction is that where the
words of a statute is clear, plain and free from ambiguity, it must be given its literal meaning and applied
without attempted interpretation. It is a well-settled principle of constitutional construction that the
language employed in the Constitution must be given their ordinary meaning except where technical
terms are employed. It is clear therefore, that the Constitution mandates that the JBC be composed of 7
members only.

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G.R. No. L-39419 April 12, 1982

MAPALAD AISPORNA, petitioner.

vs.
THE COURT OF APPEALS & THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS:

 Appellant’s husband, Rodolfo S. Aisporna was duly licensed by Insurance Commission as agent to Perla
Compania de Seguros.
 Personal Accident Policy was issued by Perla thru its author representative, Rodolfo for a period of 12
months with beneficiary as Ana M. Isidro.
 For reasons not explained in the record, information was filed by Fiscal, with assistance of private
prosecutor, charging wife of Rodolfo with violation of Sec. 189 of Insurance Law, for having willfully,
unlawfully, and feloniously, acted as agent in the solicitation for insurance by soliciting therefore the
application of one Eugenio S. Isidro for and behalf of Perla Compaña de Seguro, without said accused
having first secured a certificate of authority to act as such agent from the office of the Insurance
Commission.
 During the trial, People presented evidence that was hardly disputed, aforementioned policy was issued
with active participation of appellant wife of Rodolfo.
 Appellant, in her defense, sought to show that being the wife of a true agent, she naturally helped him
in his work, as clerk, and that policy was merely a renewal and was issued because Isidro had called by
to renew, and that time, her husband, was absent and so she left a note on top of her husband’s desk to
renew.
 The trial court found herein petitioner guilty as charged. The appellate court affirmed the decision of the
trial court.

ISSUE:

 Whether or not a person can be convicted of having violated the first paragraph of Section 189 of the
Insurance Act without reference to the second paragraph of the same section. In other words, whether
or not it is necessary to determine whether or not the agent mentioned in the first paragraph of the
aforesaid section is governed by the definition of an insurance agent found on its second paragraph.

HELD:

 No. Applying then definition of an insurance agent in the second paragraph to the agent mentioned in
the first and second paragraphs would give harmony to the aforesaid three paragraphs of Section 189.
Legislative intent must be ascertained from a consideration of the statute as a whole. A statute must be
construed as to harmonize and give effect to all its provision whenever possible. This means that every
part of statute must be considered together with the other parts, and kept subservient to the general
intent of the whole enactment, not separately but independently. Considering that the definition of an
insurance agent as found in the second paragraph is also applicable agent mentioned in the first
paragraph, to receive a compensation by the agent as an essential element for violation of the first
paragraph of the aforesaid section.

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MECANO VS. COA

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49 SCRA 355 January 31, 1973

CHINA BANKING CORPORATION & TAN KIM LIONG, petitioners-appellants.

vs.
HON. WENCESLAO ORTEGA & VICENTE G. ACABAN, respondents-appellees.

FACTS:

 Vicente Acaban filed a complaint in the court against Bautista Logging Co., Inc., B & B Forest
Development Corp. and Marino Bautista for the collection of a sum of money.
 Upon motion of the plaintiff, the trial court declared the defendants in default for failure to answer
within the given period.
 To satisfy the judgment, the plaintiff sought the garnishment of the bank deposit of the defendant with
the China Banking Corp.
 A notice of garnishment was issued by the Deputy Sheriff of the trial court and served on the said bank
through which its cashier, Tan Kim Liong.
 In reply, the bank cashier invited the attention of the sheriff to the provisions of RA 1405 which allegedly
prohibits the disclosure of any information relative to bank deposits.
 Plaintiff filed a motion to cite Tan Kim Liong for contempt of court. However, the trial court denied the
motion.
 The court ordered Liong to inform the court within 5 days from receipt of the order whether or not there
is a deposit in their bank of the defendant, and if there is any, to hold the same intact and not allow
withdrawal until further order from the court.
 Liong moved to reconsider but was turned down, and in the same order, he was directed to comply with
the order of the court within 10 days from the receipt otherwise, his arrest and confinement will be
ordered.

ISSUE:

 W/O a banking institution may validly refuse to comply with a court process garnishing the bank deposit
of a judgment debtor, by invoking the provisions of RA No. 1405.

HELD:

 NO. It was not the intention of the law makers to place bank deposits beyond the reach of execution to
satisfy the final judgement. It is sufficiently clear in the discussion of the conference committee of the
Congress that the prohibition against examination of or inquiry into a bank deposit under RA 1405 does
not preclude its being garnished to insure satisfaction of a judgement. Indeed, there is no real inquiry in
such a case, and if the existence of the deposit is disclosed, the disclosure is purely incidental to the
execution process. The court merely required Tan Kim Liong to inform the them whether or not the
defendant had a deposit in their bank only for the purposes of the garnishment issued by it, so that the
bank would hold the same intact and not allow any withdrawal until further order.