KAPISANAN NG MGA MANGGAGAWA SA MANILA RAILROAD

appellant, vs.MANILA RAILROAD COMPANY, respondent appellee.

COMPANY

CREDIT

UNION,

INC., petitioner-

FACTS:
-mandamus petition dismissed by the lower court, petitioner-appellant would seek a reversal of such decision relying on what
it considered to be a right granted by Section 62 of the Republic Act No. 2023, more specifically the first two paragraphs
thereof:
(1) A member of a cooperative may, notwithstanding the provisions of existing laws, execute an agreement in favor of the cooperative authorizing his employer to deduct from the salary or wages payable to him by the employer such amount as may be
specified in the agreement and to pay the amount so deducted to the co-operative in satisfaction of any debt or other demand owing
from the member to the co-operative. (
2) Upon the exemption of such agreement the employer shall if so required by the co-operative by a request in writing and so long
as such debt or other demand or any part of it remains unpaid, make the claimant and remit forth with the amount so deducted to
the co-operative."
-

petitioner contends that under the above provisions of Rep. Act 2023, the loans granted by credit union to its members
enjoy first priority in the payroll collection from the respondent's employees' wages and salaries.
-Court ruled in favor of respondent and held that:
there is nothing in the provision of Rep. Act 2023 hereinabove quoted which provides that obligation of laborers and employees
payable to credit unions shall enjoy first priority in the deduction from the employees' wages and salaries.
The only effect of Rep. Act 2023 is to compel the employer to deduct from the salaries or wages payable to members of the
employees' cooperative credit unions the employees' debts to the union and to pay the same to the credit union.
if Rep. Act 2023 had been enacted, the employer could not be compelled to act as the collecting agent of the employees'
credit union for the employees' debt to his credit union but to contend that the debt of a member of the employees
cooperative credit union as having first priority in the matter of deduction, is to write something into the law which does
not appear.
the mandatory character of Rep. Act 2023 is only to compel the employer to make the deduction of the employees' debt
from the latter's salary and turn this over to the employees' credit union but this mandatory character does not convert the
credit union's credit into a first priority credit.
If the legislative intent in enacting pars. 1 and 2 of Sec. 62 of Rep. Act 2023 were to give first priority in the matter of payments to the
obligations of employees in favor of their credit unions, then, the law would have so expressly declared. Thus, the express
provisions of the New Civil Code, Arts. 2241, 2242 and 2244 show the legislative intent on preference of credits.
ISSUE: WON the petitioners interpretation of RA 2023 is correct?
HELD: NO
-that there is nothing in said provision from which it could be implied that it gives top priority to obligations of the nature of
that payable to petitioner, and that, therefore, respondent company did not violate the above-quoted Section 62 of
Republic Act 2023.
- The applicable provision of Republic Act No. 2023 quoted earlier, speaks for itself. There is no ambiguity.
-Petitioner-appellant cannot therefore raise any valid objection. For the lower court to view it otherwise would have been to alter
the law. That cannot be done by the judiciary. That is a function that properly appertains to the legislative branch.

-As was pointed out in Gonzaga v. Court of Appeals: "It has been repeated time and time again that where the statutory norm
speaks unequivocally, there is nothing for the courts to do except to apply it. The law, leaving no doubt as to the scope of its
operation, must be obeyed. Our decisions have consistently born to that effect.

Philiex mining corp

SC Cannot Legislate Exception

Floresca et al are the heirs of the deceased employees of Philex Mining Corporation (hereinafter referred to as Philex), who, while working at its
copper mines underground operations at Tuba, Benguet on June 28, 1967, died as a result of the cave-in that buried them in the tunnels of the
mine. Specifically, the complaint alleges that Philex, in violation of government rules and regulations, negligently and deliberately failed to take
the required precautions for the protection of the lives of its men working underground. Floresca et al moved to claim their benefits pursuant to
the Workmens Compensation Act before the Workmens Compensation Commission. They also petitioned before the regular courts and sue
Philex for additional damages. Philex invoked that they can no longer be sued because the petitioners have already claimed benefits under the
WCA.
ISSUE: Whether or not Floresca et al can claim benefits and at the same time sue.
HELD: Under the law, Floresca et al could only do either one. If they filed for benefits under the WCA then they will be estopped from
proceeding with a civil case before the regular courts. Conversely, if they sued before the civil courts then they would also be estopped from
claiming benefits under the WCA. The SC however ruled that Floresca et al are excused from this deficiency due to ignorance of the fact. Had
they been aware of such then they may have not availed of such a remedy. However, if in case theyll win in the lower court whatever award may
be granted, the amount given to them under the WCA should be deducted. The SC emphasized that if they would go strictly by the book in this
case then the purpose of the law may be defeated. Idolatrous reverence for the letter of the law sacrifices the human being. The spirit of the law
insures mans survival and ennobles him. As Shakespeare said, the letter of the law killeth but its spirit giveth life.

Justice Gutierrez dissenting

No civil suit should prosper after claiming benefits under the WCA. If employers are already liable to pay benefits under the WCA they should
not be compelled to bear the cost of damage suits or get insurance for that purpose. The exclusion provided by the WCA can only be properly
removed by the legislature NOT the SC.
Case No. 11 | Midterms Case No. 2
Elena Salenillas and Bernardino Salenillas vs CA
GR No. 78687, January 31, 1989
Statutory Rule: Between two statutory interpretations, that which better serves the purpose of the law should
prevail.
Facts:
The parents of Elena Salenillas, one of the petitioners, were grantees of free patent. The subject property
was later sold to Elena Salenillas and her husband, petitioners in the instant case. On December 4, 1973, the
property of petitioners was mortgaged to Philippine National bank as security for a loan of P2,500. For failure to pay
their loan, the property was foreclose by PNB and was bought at a public auction by private respondent. Petitioner
maintains that they have a right to repurchase the property under Sec. 119 of the Public Land Act. Respondent
states that the sale of the property disqualified petitioner from being legal heirs vis-a-vis the said property.
Issue:
W/N petitioners have the right to repurchase the property under Sec. 119 of the Public Land Act.
Held:

Yes. Sec. 119 of the Public Land Act provides that "every conveyance of land acquired under the free
patent or homestead provisions shall be subject to repurchase by the applicant, his widow or legal heirs within a
period of five years from the date or conveyance." The provision makes no distinction between the legal heirs. The

distinction made by respondent contravenes the very purpose of the act. Between two statutory interpretations,
that which better serves the purpose of the law should prevail.

RCPI vs NTC Case Digest

RADIO COMMUNICATIONS OF THE PHILIPPINES, INC. (RCPI) vs. NATIONAL TELECOMMUNICATIONS COMMISSION (NTC)
and JUAN A. ALEGRE
G.R. No. 93237 November 6, 1992
Facts: Private respondent Juan A. Alegre's wife, Dr. Jimena Alegre, sent two (2) RUSH telegrams through petitioner RCPI's facilities
in Taft Ave., Manila at 9:00 in the morning of 17 March 1989 to his sister and brother-in-law in Valencia, Bohol and another sister-inlaw in Espiritu, Ilocos Norte.
Both telegrams did not reach their destinations on the expected dates. So, private respondent filed a letter-complaint against RCPI
with National Telecommunications Commission (NTC) for poor service, with a request for the imposition of the appropriate punitive
sanction against the company. Taking cognizance of the complaint, NTC directed RCPI to answer the complaint and set the initial
hearing.
NTC held that RCPI was administratively liable for deficient and inadequate service under Section 19(a) of C.A. 146 and imposed
the penalty of fine payable within thirty (30) days from receipt in the aggregate amount of one thousand pesos.
Hence, RCPI filed this petition for review invoking C.A. 146 Sec. 19(a) which limits the jurisdiction of the Public Service Commission
(precursor of the NTC) to the fixing of rates.
ISSUE: Whether or not Public Service Commission (precursor of the NTC) has jurisdiction to impose fines
HELD: The decision appealed from is reversed and set aside for lack of jurisdiction of the NTC to render it.
NTC has no jurisdiction to impose a fine. Under Section 21 of C. A. 146, as amended, the Commission was empowered to impose
an administrative fine in cases of violation of or failure by a public service to comply with the terms and conditions of any certificate
or any orders, decisions or regulations of the Commission. Petitioner operated under a legislative franchise, so there were no terms
nor conditions of any certificate issued by the Commission to violate. Neither was there any order, decision or regulation from the
Commission applicable to petitioner that the latter had allegedly violated, disobeyed, defied or disregarded.
No substantial change has been brought about by Executive Order No. 546 invoked by the Solicitor General's Office to bolster
NTC's jurisdiction. The Executive Order is not an explicit grant of power to impose administrative fines on public service utilities,
including telegraphic agencies, which have failed to render adequate service to consumers. Neither has it expanded the coverage of
the supervisory and regulatory power of the agency. There appears to be no alternative but to reiterate the settled doctrine in
administrative law that:
Too basic in administrative law to need citation of jurisprudence is the rule that jurisdiction and powers of administrative agencies,
like respondent Commission, are limited to those expressly granted or necessarily implied from those granted in the legislation
creating such body; and any order without or beyond such jurisdiction is void and ineffective (Globe Wireless case).
Macabenta vs. Davao Stevedore Terminal Co., G.R. No. L-27489, April 30,1970
Objects and Methods of Construction: Mens Legislatoris/Mischief Rule
It is a principle of statutory construction that what is within the spirit of the law is as much a part of it as what is
written. Otherwise the basic purpose discernible in such codal provision would not be attained.
Facts: Conrado Macabenta was a laborer in the sawmill of the Davao Stevedore Terminal Company. Although some
sort of quarters were provided by the respondent to its employees at the sawmill, many of them apparently
preferred to commute (the Company furnishes their transportation), and the deceased in particular went home
about three times a week.
At the time that the decedent met the vehicular accident on September 13, 1961 which led to his death on
September 29, 1961, the claimant-widow, Leonora Tantoy Vda. de Macabenta, was not yet married to the decedent
although they had already been living together as husband and wife for the past three months. However, on the

day following the accident, they were lawfully wedded in a marriage ceremony solemnized in the hospital where the
deceased was hospitalized up to his death. The claimant widow gave birth on April 8, 1962 to the posthumous
daughter of the deceased who was given the name Raquel Tantoy Macabenta. The Workmen's Compensation
Commission awarded to the claimant widow for herself and in behalf of her minor child the amount of P2,708.00 as
compensation and the sum of P270.80 as attorney's fees.
Issue:
Whether or not the widow of a deceased employee whose marriage occurred after the accident as well as the
posthumous child could be considered dependents within the meaning of the Workmen's Compensation Act.
Held:
Yes. From the express language of the Workmen's Compensation Act, a widow living with the deceased or
actually dependent upon him totally or partly as well as her daughter, if under 18 years of age or incapable of
supporting him or herself, and unmarried, whether or not actually dependent upon the deceased are considered
dependents.
Ratio:
It is true that the marriage took place after the fatal accident but there was no question that at the time of his death
she was married to him. She, therefore, comes entirely within the letter of the law. Nor can there be any doubt that
the child, Raquel Macabenta, also falls within the words the Act employs. Our Civil Code, in no uncertain terms,
considers a conceived child born for all purposes that are favorable to her provided the birth is attended with the
conditions specified, namely, that she is alive at the time she is completely delivered from the mother's womb.
Time and time again, we have stressed that where the law is clear, our duty is equally plain. We must apply
it to the facts as found. What is more, we have taken pains to defeat any evasion of its literal language by
rejecting an interpretation, even if not totally devoid of plausibility, but likely to attach to it a significance different
from that intended by the lawmakers. A paraphrase of an aphorism from Holmes is not inappropriate. There can
always occur to an intelligence hostile to a piece of legislation a misinterpretation that may, without due reflection,
be considered not too far-fetched.
Our conclusion likewise finds support in the fundamental principle that once the policy or purpose of the law
has been ascertained, effect should be given to it by the judiciary. Even if honest doubts could be
entertained, therefore, as to the meaning of the statutory provisions, still respect for such a basic doctrine calls for
a rejection of the plea of the Davao Stevedore Terminal Company. Assuming a choice is necessary between
conflicting theories, that which best conforms to the language of the statute and its purpose should
prevail.
To quote from the Lingad case anew: For it is undeniable that every statute, much more so one arising from a
legislative implementation of a constitutional mandate, must be so construed that no question as to its
conformity with what the fundamental law requires need arise.
Paras v. COMELEC
G.R. No. 123169, November 4, 1996
Ponente: Justice Francisco

Facts:
Petitioner is the incumbent barangay captain of Pula, Cabanatuan City who won during the last regular barangay election in 1994. A petition for
his recall was filed by the registered voters of the barangay. A recall election was set, against which petitioner filed a petition. Petitioner cites
Section 74 (b) of LGC, which states that no recall shall take place within one (1) year from the date of the officials assumption to office or one
(1) year immediately preceding a regular local election, petitioner insists that the scheduled January 13, 1996 recall election is now barred as the
Sangguniang Kabataan (SK) election was set by Republic Act No. 7808 on the first Monday of May 1996, and every three years thereafter.

Petitioner maintains that as the SK election is a regular local election, hence no recall election can be had for barely four months separate the SK
election from the recall election. We do not agree.

Issue:
Whether or not an SK election is a regular election.

Held:
No. A statutes provisions must be considered with the other parts and must be kept subservient to the general intent of the whole enactment.
Paragraph (b) with (a) of LGC74 merely designates such a period, i.e. 2nd year of term. Considering the SK election as regular will unduly
circumscribe the LGC provision on recall. No recall election can be conducted if that is the case (May 1996, every three years). It is assumed that
legislature intended to enact an effective law, and interpretation should give effec to the intent, with the whole statute. It is likewise a basic
precept in statutory construction that a statute should be interpreted in harmony with the Constitution. [7] Thus, the interpretation of Section 74 of
the Local Government Code, specifically paragraph (b) thereof, should not be in conflict with the Constitutional mandate of Section 3 of Article
X of the Constitution to enact a local government code which shall provide for a more responsive and accountable local government structure
instituted through a system of decentralization with effective mechanisms of recall, initiative, and referendum x x x. An interpretation too literal
that the spirit is denied will fall in former of the latter.

Kapisanan ng mga Manggagawa sa Manila Railroad Company Credit Union,

Inc. Vs Manila Railroad Company.
Facts: Petitioner-Appellant, Kapisanan ng mga Manggagawa sa Manila
Railroad Company Credit Union, Inc. seeks to establish a right
granted by section 62 of the Republic Act No. 2023, that the
petitioner contends that under the provisions of R.A 2023, the loans
granted by credit unions to its members enjoy the first priority in
the payroll collection from the respondent's employees' wages
and
salaries.
Issues: 1. whether or not R.A 2023 provides first priority in the
matter of payments to the obligations of employees in favor of their
credit unions?
2. whether or not the petition for mandamus is clear and
certain?
Ruling: 1. No. The applicable provision of R.A 2023 speaks for
itself. There is no ambiguity. Petitioner-Appellant cannot therefore
raise any valid objection. And the lower court cannot view it
otherwise for it would be to alter the law, it cannot be done by the
judiciary.
2. No. Petitioner-Appellant was unable to show a clear legal
right, the very law on which he would base his action fails to
supply any basis for this petition. If the legal rights of the
petitioner are not well defined, clear, and certain, the petition
must be dismissed.