Case Principle/Doctrine

1 Caltex v. Palomar Definition of construction and

interpretation
II. CONSTRUCTION DISTINGUISHED FROM INTERPRETATION
Construction and interpretation have the same purpose and that is to ascertain and give effect to the
legislative intent. A distinction, however, has been drawn between construction and interpretation.
One who interprets makes use of intrinsic aids or those found in the statute itself, while one who
constructs makes use of extrinsic aids or those found outside of the written language of the law
(Caltex [Philippines], Inc. v. Palomar, L-19650, September 29, 1966)
eSCRA
Statutes; Construction defined.—Construction is the art or process of discovering and expounding the
meaning 'and intention of the authors of the law with respect to its applica-tion to a given case, where
that intention is rendered doubtful, amongst others, by reason of the fact that the given case is not
explicitly provided for in the law (Black, Interpretation of Laws, p. 1). In the present case, the
question of whether or not the scheme proposed by the appellee is within the coverage of the
prohibitive provisions of the Postal Law inescapably requires an inquiry into the intended meaning of
the words used therein. This is as much a question of construction or interpretation as any other.
2 Songco v. NLRC Construction is a judicial function.
When the law is clear, apply.
Construction of labor laws
In Songco, et al. v. National Labor Relations Commission,
the Supreme Court said: "When the law speaks in clear and categorical language, there is no room for
interpretation or construction. There is only room for application. A plain and unambiguous statute
speaks for itself, and any attempt to make it clearer is vain labor and tends only to obscurity." (G.R.
Nos. 50999-5100, March 23, 1990)
• LABOR LEGISLATION AND LABOR CONTRACTS SHALL BE CONSTRUED IN
FAVOR OF THE SAFETY AND DECENT LIVING OF THE LABORER
Article 4 of the Labor Code which states that "all doubts in the implementation and interpretation of
the provision of the Labor Code including its implementing rules and regulations shall be resolved in
favor of labor, and Article 1702 of the Civil Code which provides that "in case of doubt, all labor
legislation and all labor contracts shall be construed in favor of the safety and decent living for the
laborer."
3 Mantrade FMMC Division Executive dept may construe in
Employee and Workers order to enforce the statute but
Union v. Bacungan Construction is a judicial function.
Construction of labor laws
I. WHO INTERPRETS THE LAW?
Anyone can interpret the law. Lawyers, policemen, arbiters, administrative boards and agencies,
government as well as private executives are involved from time to time in the interpretation of laws.
Their interpretation, however, is not necessarily conclusive nor can they bind the courts. Hence, in
many occasions, the decisions of regulatory boards and administrative agencies have been elevated
and appealed to the Supreme Court in cases where there is abuse of discretion and authority or when
there is a violation of due process or denial of substantial justice or erroneous interpretation of the law
(MantradeFMMC Division Employee and Workers Union v. Bacungan, G.R. No. L-48437, September
30, 1986, Second Division, Feria, J.).

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 Case Principle/Doctrine

4 Conde v. IAC Construction of labor laws

VI. WHO INTERPRETS THE LAW?
The judiciary has the delicate task of ascertaining the significance of a constitutional or statutory
provision, an executive order, a procedural or a municipal ordinance. It discharges a role no crucial
than the roles played by the two other departments in maintaining the rules of law. To assure stability
in legal relations and avoid confusion, it has to speak with one voice. Logically and rightly, it does so
with finality through the highest judicial organ, the Supreme Court. What it says is definite and
authoritative, binding on those who occupy the lower ranks in the judicial hierarchy (Conde v.
Intermediate Appellate Court, G.R. No. 70443, September 15, 1986, Second Division, Gutierez, Jr.,
J.).
5 Bolos v. Bolos When the law is clear, apply.
A cardinal rule in statutory construction is that when the law is clear and free from any doubt or
ambiguity, there is no room for construction or interpretation. There is only room for application. As
the statute is clear, plain, and free from ambiguity, it must be given its literal meaning and applied
without attempted interpretation. This is what is known as the plain-meaning rule or verba legis. It is
expressed in the maxim, index animi sermo, or "speech is the index of intention." Furthermore, there
is the mmm verbs legis ,ion et recedendum, or "from the words of a statute there should be no
departure."
eSCRA
Same; Same; Same; Statutory Construction; Verba Legis (Plain Meaning Rule); A cardinal rule in
statutory construction is that when the law is clear and free from any doubt or ambiguity, there is no
room for construction or interpretation—there is only room for application.—The Court finds Itself
unable to subscribe to petitioner’s interpretation that the phrase “under the Family Code” in A.M. No.
02-11-10-SC refers to the word “petitions” rather than to the word “marriages.” A cardinal rule in
statutory construction is that when the law is clear and free from any doubt or ambiguity, there is no
room for construction or interpretation. There is only room for application. As the statute is clear,
plain, and free from ambiguity, it must be given its literal meaning and applied without attempted
interpretation. This is what is known as the plain-meaning rule or verba legis. It is expressed in the
maxim, index animi sermo, or “speech is the index of intention.” Furthermore, there is the
maxim verba legis non est recedendum, or “from the words of a statute there should be no departure.”
6 Vicencio v. Villar When the law is clear, apply.
eSCRA
Statutory Construction; Where the words of a statute are clear, plain, and free from ambiguity, it must
be given its literal meaning and applied without attempted interpretation.—Where the words of a
statute are clear, plain, and free from ambiguity, it must be given its literal meaning and applied
without attempted interpretation. Thus, the ordinance should be applied according to its express
terms, and interpretation would be resorted to only where a literal interpretation would be either
impossible or absurd or would lead to an injustice. In the instant case, there is no reason to depart
from this rule, since the subject ordinance is not at all impossible, absurd, or unjust.

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7 National Federation of Labor No construction When the law is clear, apply.

v. Eisma

In the case of National Federation of Labor v. Eisma,14 the Court ruled that Article 217 is to be
applied the way it is worded. The exclusive original jurisdiction of a labor arbiter is therein provided
for explicitly. It means, it can only mean, that a court of first instance judge then, a regional trial court
judge now, certainly acts beyond the scope of the authority conferred on him by law when he
entertained the suit for damages, arising from picketing that accompanied a strike. That was squarely
within the express terms of the law. Any deviation cannot therefore be tolerated.
eSCRA
Same; Same.—The issuance of Presidential Decree No. 1691 and the enactment of Batas Pambansa
Blg. 130, made clear that the exclusive and original jurisdiction for damages would once again be
vested in labor arbiters. It can be affirmed that even if they were not that explicit, history has
vindicated the view that in the appraisal of what was referred to by Philippine American Management
& Financing Co., Inc. v. Management & Supervisors Association of the Philippine-American
Management & Financing Co., Inc. as “the rather thorny question as to where in labor matters the
dividing line is to be drawn” between the power lodged in an administrative body and a court, the
unmistakable trend has been to refer it to the former. Thus: “Increasingly, this Court has been
committed to the view that unless the law speaks clearly and unequivocally, the choice should fall on
[an administrative agency].” Certainly, the present Labor Code is even more committed to the view
that on policy grounds, and equally so in the interest of greater promptness in the disposition of labor
matters, a court is spared the often onerous task of determining what essentially is a factual matter,
namely, the damages that may be incurred by either labor or management as a result of disputes or
controversies arising from employer-employee relations.
8 Tarlac Development Corp. v. Ambiguity Defined
CA
X. AMBIGUITY DEFINED
Ambiguity is doubtfulness, doubleness of meaning, indistinctness or uncertainty of meaning of an
expression used in a written in- strument. (Black's Law Dictionary, 4th Edition, p. 105) It has been
held, however, that ambiguity does not only arise from the meaning of the particular words but also
from the general scope and meaning of the statute when all its provisions are examined. There is also
an ambiguity when a literal interpretation of the words would lead to unreasonable, unjust or absurd
consequences, or where a statute is in conflict with the Constitution, or where the statute would defeat
the policy of the legislation. (Tarlac Development Corporation v. CA, L-41012, September 30, 1976)
9 Accenture v. CIR
eSCRA
Statutory Construction; The interpretation of a law by the Supreme Court constitutes part of that law
from the date it was originally passed, since this Court’s construction merely establishes the
contemporaneous legislative intent that the interpreted law carried into effect.—When this Court
decides a case, it does not pass a new law, but merely interprets a preexisting one. When this Court
interpreted Section 102(b) of the 1977 Tax Code in Burmeister, this interpretation became part of the
law from the moment it became effective. It is elementary that the interpretation of a law by this
Court constitutes part of that law from the date it was originally passed, since this Court’s
construction merely establishes the contemporaneous legislative intent that the interpreted law carried
into effect.

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 Case Principle/Doctrine

10 Philippines Today Inc, v. Interpretation is always in the

NLRC context of each case.
eSCAR
Courts; Statutory Construction; In deciding cases, the Supreme Court does not matter-of-factly apply
and interpret laws in a vactum—laws are interpreted always in the context of the peculiar factual
situation of each case.—ln deciding cases, this Court does not matter-of-factly apply and interpret
laws in a vacuum. General principles do not decide specific cases. Rather, laws are interpreted always
in the context of the peculiar factual situation of each case. Each case has its own flesh and blood and
cannot be decided simply on the basis of isolated clinical classroom principles. The circumstances of
time, place, event, person, and particularly attendant circumstances and actions before, during and
after the operative fact should all be taken in their totality so that justice can be rationally and fairly
dispensed.
11 Endencia v. David Construction is a judicial function.
Congress cannot, by law, modify an interpretation of the Constitution made by the court.
“If the legislature may declare what a law means, or what a specific portion of the Constitution
means, especially after the courts have in actual case ascertained its meaning by interpretation and
applied it in a decision, this would surely cause confusion.” (Endencia v. David)
eSCRA
Separation of Powers—Under our system of constitutional government, the Legislative department is
assigned the power to make and enact laws. The Executive department is charged with the execution
or carrying out of the provisions of said laws. But the interpretation and application of said laws
belong exclusively to the Judicial department. And this authority to interpret and apply the laws
extends to the Constitution. Before the courts can determine whether a law is constitutional or not, it
will have to interpret and ascertain the meaning not only of said law, but also of the pertinent portion
of the Constitution in order to decide whether there is a conflict between the two, because if there is,
then the law will have to give way and has to be declared invalid and unconstitutional.

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