Validity of Statutes – Statutory Construction

SALAS V JARENCIO
G.R. No. L-29788, AUGUST 30, 1972

Exec. Sec. Rafael Salas filed a petition for review of the decision of the Court of First Instance (CFI) -
Manila dated 23 September 1968 which ruled that Republic Act No. 4118 (HB No. 1453) is
UNSCONSTITUTIONAL for depriving the City of Manila, a parcel of land known as Lot No. 1 Block 557.
Petitioner Salas et. al seeks to reverse the decision of the CFI and therefore declare RA No. 4118 as
constitutional and proceed with its implementation.

FACTS:
 The City of Manila had a Transfer of Certificate Title No. 22547 over a 7,450 square meter lot—
which was the remaining portion of Lot No. 1. The other portions of Lot No.1 had already been
sold.
 In September 1960, the Municipal Board of Manila requested the President of the Philippines to
have the remaining area/lot declared as patrimonial property (disposable or alienable property) of
the City of Manila so that it could be sold by the City of Manila to the actual occupants of the lot.
 Afterwards, a revised version of the Bill was introduced in the House of Representatives as
House Bill No. 1453 which seeks to convert one (1) parcel of land in the district of Malate, which
is reserved as communal property into a patrimonial property (disposable or alienable property)
of the State (not of the City of Manila) and to provide its subdivision and sale to bona fide
occupants or tenants. Its disposal was given to a national government entity, the Land Tenure
Administration (Land Authority).
 The bill was passed by the Senate, approved by the President on June 1964 and became
Republic Act No. 4118. To implement this, then Gov. Yap of the Land Authority wrote a letter to
then Manila City Mayor Antonio Villegas for the proposed subdivision plan which the City of
Manila accepted.
 But due to unknown reasons, the City of Manila decided to go against their agreement and
brought an action for injunction and/or prohibition with preliminary injunction to restrain, prohibit
and enjoin the appellants from further implementing Republic Act No. 4118, and praying for the
declaration of it as unconstitutional.

Respondent Judge Jarencio declared that RA 4118 is unconstitutional and invalid, thus the petition for
review.

ISSUE/S:

Is Republic Act No. 4118 is constitutional?

RULING:

Yes. The City of Manila has not provided any evidence that it acquired said land as a private or
patrimonial property. In addition, RA 4118 was intended to implement the social justice policy of the
Constitution. The implementation of RA 4118 was never intended to confiscate/expropriate the property
involved but merely to prove its character as a communal land of the State and to make it available for
disposition by the National Government through the Land Authority.

Principle/Doctrine in Statutory Construction: Presumption of Constitutionality/Validity of Statutes

Presumption of Constitutionality of a statute or provision is followed when two possible interpretations of
a statute occur –one in violation of the Constitution and one in favor of the Constitution.1 Every statute is
presumed valid. The reason lies in the very essence of how a law is enacted. Before legislature passes a
bill, it is presumed that it has decided the measure to be constitutional; and when the President approves
the bill, it is presumed that he has been convinced of its validity. An act of the legislature, approved by
the President, is presumed to be within the constitutional limitations.2

1 http://jurip.org/wp-content/uploads/2017/12/Shuwakitha-Chandrasekaran.pdf
2 Statutory Construction by Ruben Agpalo