Malanyaon v. Lising et. al Case No. 160 GR No.

L-56028 (July 30,1981)

Terms with multiple meaning
FACTS: A Municipal Mayor was charged with violation of RA 3019 (Anti Graft and
Corrupt Practices Act). He was suspended from office but he died during his
incumbency, and while the case was pending. The case was dismissed due to his
death. Petitioner sought payment of his salary during his period of suspension
pursuant to Sec 13 of RA 3019 which provides, Should he be convicted by final
judgment he shall lose all retirement or gratuity benefits under any law, but if he is
acquitted, he shall be entitled to reinstatement and to the salaries and benefits w/c
he failed to receive during suspension.
ISSUE: W/N the dismissal of the case due to death of the accused constitutes
acquittal.
HELD: No. It is obvious that when the statute speaks of the suspended officer being
"acquitted" it means that after due hearing and consideration of the evidence
against him the court found that his guilt has not been proven beyond reasonable
doubt. Dismissal of the case is not equal to acquittal of the accused. In People vs.
Salico (84 Phil. 722), " Acquittal is always based on the merits but dismissal does
not decide the case on the merits or that the defendant is not guilty.

Doctrine of Associated Words or Noscitur Sociis

Caltex (Phil.), Inc. v. Palomar Case No. 45 G.R. No. 19650 (September 29,
1966)
FACTS: Petitioner conceived the Caltex Hooded Pump Contest where participants
have to estimate the actual number of liters a hooded gas pump can dispense
during a specific period of time. There was no fee or consideration required to be
paid, nor any purchase of any Caltex products to be made in order to join the
contest. Foreseeing the extensive use of mail for advertising and communications,
Caltex requested clearance for Respondent Postmaster General but was denied
citing said contest is a gift enterprise deemed as a non-mailable matter under the
anti-lottery provisions of the Postal Law. Hence, Petitioner filed a petition for
declaratory relief.
ISSUE: W/N the Caltex Hooded Pump Contest falls under the term gift
enterprise which is banned by the Postal Law.
HELD: No, said contest is not a gift enterprise. The word lottery is defined as a
game of chance where the elements of which are (1) consideration, (2) chance, and
(3) prize. The term gift enterprise and scheme in the provision of the Postal Law
making unmailable any lottery, gift, enterprise, or scheme for the distribution of
money or any real or personal property by lot, chance, or drawing of any kind
means such enterprise as will require consideration as an element. The intent of the
prohibition is to suppress the tendency to inflame the gambling spirit and to corrupt

public morals. There being no element of consideration in said contest, the spirit of
the law is preserved.

Expressio Unius Exclusio Alterius Rule

Manabat v. De Aquino Case No. 161 G.R. No. L-5558 (April 29, 1953)
FACTS: Petitioners were ordered to pay P 1,261.74 plus interest for usury, wherein
the couple failed to appear in court and present evidence in the hearing. Notified of
the decision on September 7, 1951, they filed for an appeal by registered mail on
September 22 of that same year. However, the papers were actually received by the
court on September 24. Thus, the Judge of First Instance declared that the appeal
was late and dismissed it.
ISSUE: 1. Whether the appeal was deemed filed on September 22, when they were
deposited by registered mail, or Sept 24, when they were actually received by the
court. 2. W/N the appeal has been perfected within 15 days.
HELD: Yes. The appeal was perfected within 15 days. Rule 27 Sec. 1 of the Rules of
Court must be applied which will result to the date of deposit in the post office by
registered mail of court papers as the date of filing. Uniformity of rules is to be
desired to simplify procedure. Thus, Petitioners filed their appeal just in time.

Centano v. Villalon-Pornillos Case No. 54 G.R. No. 113092 (September 1,

1994)
FACTS: In 1985, the officers of Samahang Katandaan ng Nayon ng Tikay launched a
fund drive for the purpose of renovating the chapel of Barrio Tikay in Bulacan.
Martin Centeno, chairman of the group, approached Judge Angeles, President of
Tikay, and the latter solicited P 1,500. However, this solicitation was made without a
permit from the DSWD and as a result, it was contended that Centeno violated P.D.
1564, which states Any person to solicit or receive contributions for charitable or
public welfare purposes shall secure a permit from the regional Office of the
Department of Social services and Development.
ISSUE: W/N the phrase charitable purposes in P.D. 1564 is meant to include
religious purposes.
HELD: No. Where a statute is expressly limited to certain matters, it may not, by
interpretation or construction, be extended to others. The 1987 Constitution treats
the words charitable and religious separately and independently from each

other. Since P.D. 1564 merely states that charitable or public welfare purposes need
a permit from DSWD, this means that the framers of the law never intended to
include solicitations for religious purposes within its coverage. The term charitable
should be strictly construed to exclude solicitations for religious purposes.
Moreover, since this is a criminal case, penal law must be construed strictly against
the State and liberally in favor of the accused