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6. People vs. Guillermo Manantan [G.R. No L-14129.

July 31, 1962] Respondent union alleges that instead of multiplying the COLA by 22 it should be multiplied by 30 representing the
number of days in a month, as what the corporation's normal practice prior to the said Wage Order. Thus the union filed
FACTS: [D]efendant Guillermo Manantan was charged with a violation Section 54 of the Revised Election Code in the a complaint against the Corporation for for illegal deduction, underpayment, unpaid allowances, and violation of Wage
Court of First Instance of Pangasinan. The defense moved to dismiss the information on the ground that as justice of the Order No. 6.
peace the defendant is one of the officers enumerated in Section 54 of the Revised Election Code. The lower court denied
the said motion. A second motion was filed by defense counsel who cited in support thereof the decision of the Court of Issue: Whether or not COLA under Wage Order No. 6 should be multiplied by 22 or 30 representing the number of
Appeals in People vs. Macaraeg applying the rule of “expressio unius, est exclusion alterius”. The lower court dismissed working days in a month.
the information against the accused upon the authority of the ruling in the case cited by the defense. The issue was raised
to the Supreme Court. Held: Labor Arbiter Adelaido F. Martinez sustained the position of Petitioner Corporation by holding that since the
individual petitioners acted in their corporate capacity they should not have been impleaded; and that the monthly
ISSUE: Whether or not a justice of the peace was included in the prohibition of Section 54 of the Revised Election Code. COLA should be computed on the basis of twenty two (22) days, since the evidence showed that there are only 22 paid
days in a month for monthly-paid employees in the company. His reasoning, inter alia, was as follows:
HELD: YES. The order of dismissal entered by the trial court should be set aside and this case was remanded for trial on
the merits. To compel the respondent company to use 30 days in a month to compute the allowance and retain 22 days for vacation
and sick leave, overtime pay and other benefits is inconsistent and palpably unjust. If 30 days is used as divisor, then it
RATIO: The application of the rule of casus omissus does not proceed from the mere fact that a case is criminal in nature, must be used for the computation of all benefits, not just the allowance. But this is not fair to complainants, not to mention
but rather from a reasonable certainty that a particular person, object or thing has been omitted from a legislative that it will contravene the provision of the parties' CBA.
enumeration. In the present case, and for reasons already mentioned, there has been no such omission. There has only
been a substitution of terms. On law reason and public policy, defendant-appellee’s contention that justices of the peace Section 5 of the Rules Implementing Wage Orders Nos. 2, 3, 5 and 6 uniformly read as follows:
are not covered by the injunction of Section 54 must be rejected. To accept it is to render ineffective a policy so clearly Section 5. Allowance for Unworked Days. All covered employees shall be entitled to their daily living allowance during
and emphatically laid down by the legislature. the days that they are paid their basic wage, even if unworked. (Emphasis supplied)

Although it was observed that both the Court of Appeals and the trial court applied the rule of “expressio unius, est ... it is evident that the intention of the law is to grant ECOLA upon the payment of basic wages. Hence, we have the
exclusion alterius” in arriving at the conclusion that justices of the peace are not covered by Section 54, the rule has no principle of 'No Pay, No ECOLA.
application. If the legislature had intended to exclude a justice of the peace from the purview of Section 54, neither the
trial court nor the Court of Appeals has given the reason for the exclusion. Indeed, there appears no reason for the alleged MM Promotions and Management Inc. vs. NLRC and Delos Santos [G.R. No. 109835. November 22, 1993]
change. Hence, the rule of expressio unius est exclusion alterius has been erroneously applied.
FACTS: Petitioner’s appeal was dismissed by the respondent National Labor Relations Commission citing the second
Socorro Ramirez vs. CA and Garcia [G.R. No. 93833. September 28, 1995] paragraph of Article 223 of the Labor Code as amended and Rule VI, Section 6 of the new Rules of Procedure of the
NLRC, as amended. The petitioner contends that the NLRC committed grave abuse of discretion in applying these rules
FACTS: Petitioner made a secret recording of the conversation that was part of a civil case filed in the Regional Trial to decisions rendered by the POEA. It insists that the appeal bond is not necessary in the case of licensed recruiters for
Court of Quezon City alleging that the private respondent, Ester S. Garcia, vexed, insulted and humiliated her in a overseas employment because they are already required under Section 4, Rule II, Book II of the POEA Rules not only to
“hostile and furious mood” and in a manner offensive to petitioner’s dignity and personality,” contrary to morals, good pay a license fee of P30,000 but also to post a cash bond of P100,000 and a surety bond of P50,000. In addition, the
customs and public policy.”. Private respondent filed a criminal case before the Regional Trial Court of Pasay City for petitioner claims it has placed in escrow the sum of P200,000 with the Philippine National Bank in compliance with
violation of Republic Act 4200, entitled “An Act to prohibit and penalize wire tapping and other related violations of Section 17, Rule II, Book II of the same Rule, “to primarily answer for valid and legal claims of recruited workers as a
private communication, and other purposes.” Petitioner filed a Motion to Quash the Information. The trial court granted result of recruitment violations or money claims.” The Solicitor General sustained the appeal bond and commented that
the said motion. The private respondent filed a Petition for Review on Certiorari with the Supreme Court, which referred appeals from decisions of the POEA were governed by Section 5 and 6, Rule V, Book VII of the POEA Rules.
the case to the Court of Appeals in a Resolution. Respondent Court of Appeals promulgated its decision declaring the
trial court’s order as null and void, after subsequently denied the motion for reconsideration by the petitioner. ISSUE: Whether or not the petitioner is still required to post an appeal bond to perfect its appeal from a decision of the
POEA to the NLRC?
ISSUE: Whether or not the applicable provision of Republic Act 4200 does not apply to the taping of a private
conversation by one of the parties to the conversation. HELD: YES. Petitioner’s contention has no merit.

HELD: NO. Petition denied. Costs against petitioner. RATIO: Statutes should be read as a whole. Ut res magis valeat quam pereat – that the thing may rather have effect than
RATIO: Legislative intent is determined principally from the language of the statute.The unambiguity of the express be destroyed.
words of the provision, taken together with the above-quoted deliberations from the Congressional Record, therefore
It is a principle of legal hermeneutics that in interpreting a statute (or a set of rules as in this case), care should be taken
plainly supports the view held by the respondent court that the provision seeks to penalize even those privy to the private
that every part thereof be given effect, on the theory that it was enacted as an integrated measure and not as a hodge-
communications. Where the law makes no distinctions, one does not distinguish.
podge of conflicting provisions. Under the petitioner’s interpretation, the appeal bond required by Section 6 of the POEA
[P]etitioner’s contention that the phrase “private communication” in Section 1 of R.A. 4200 does not include “private
Rule should be disregarded because of the earlier bonds and escrow money it has posted. The petitioner would in effect
conversations” narrows the ordinary meaning of the word “communication” to a point of absurdity.
nullify Section 6 as a superfluity but there is no such redundancy. On the contrary, Section 6 complements Section 4 and
GLOBE MACKAY CABLE AND RADIO CORPORATION, FREDERICK WHITE and JESUS SANTIAGO 
vs.
 Section 17. The rule is that a construction that would render a provision inoperative should be avoided. Instead,
NATIONAL LABOR RELATIONS COMMISSION, FFW-GLOBE MACKAY EMPLOYEES UNION and EDA apparently inconsistent provisions should be reconciled whenever possible as parts of a coordinated and harmonious
CONCEPCION whole.
Facts:On October 30, 1984 Wage Order No. 6 mandated an increased in the cost-of-living allowance of non-agricultural
workers in the private sector for P3.00. The order was complied by the petitioner Corporation by multiplying the same
by 22 days, equivalent to the number of working days in the company.
Chua vs. CSC and NIA [G.R. No. 88979. February 07, 1992] Sec. 3 of R.A. 7166 will have to continue to be elected at large in the May 11, 1992, elections, although starting 1995 they
shall all be elected by district to effect the full implementation of the letter and spirit of R.A. 7166.
FACTS: Republic Act No. 6683 provided benefits for early retirement and voluntary separation from the government
service as well as for involuntary separation due to reorganization. Deemed qualified to avail of its benefits are those People vs. Guillermo Manantan [G.R. No L-14129. July 31, 1962]
enumerated in Sec. 2 of the Act. Petitioner Lydia Chua believing that she is qualified to avail of the benefits of the
program, filed an application with respondent National Irrigation Administration (NIA) which, however, denied the FACTS:[D]efendant Guillermo Manantan was charged with a violation Section 54 of the Revised Election Code in the
same; instead, she was offered separation benefits equivalent to one half (1/2) month basic pay for every year of service Court of First Instance of Pangasinan. The defense moved to dismiss the information on the ground that as justice of the
commencing from 1980, or almost fifteen (15) years in four (4) successive governmental projects. A recourse by petitioner peace the defendant is one of the officers enumerated in Section 54 of the Revised Election Code. The lower court denied
to the Civil Service Commission yielded negative results, citing that her position is co-terminous with the NIA project the said motion. A second motion was filed by defense counsel who cited in support thereof the decision of the Court of
which is contractual in nature and thus excluded by the enumerations under Sec.3.1 of Joint DBM-CSC Circular Letter Appeals in People vs. Macaraeg applying the rule of “expressio unius, est exclusion alterius”. The lower court dismissed
No. 89-1, i.e. casual, emergency, temporary or regular employment. Petitioner appealed to the Supreme Court by way of the information against the accused upon the authority of the ruling in the case cited by the defense. The issue was raised
a special civil action for certiorari. to the Supreme Court.

ISSUE: Whether or not the petitioner is entitled to the benefits granted under Republic Act No. 6683. ISSUE: Whether or not a justice of the peace was included in the prohibition of Section 54 of the Revised Election Code.

HELD: YES. Petition was granted. HELD: YES. The order of dismissal entered by the trial court should be set aside and this case was remanded for trial on
the merits.
RATIO: Petitioner was established to be a co-terminous employee, a non-career civil servant, like casual and emergency
employees. The Supreme Court sees no solid reason why the latter are extended benefits under the Early Retirement Law RATIO: The application of the rule of casus omissus does not proceed from the mere fact that a case is criminal in nature,
but the former are not. It will be noted that Rep. Act No. 6683 expressly extends its benefits for early retirement to regular, but rather from a reasonable certainty that a particular person, object or thing has been omitted from a legislative
temporary, casual and emergency employees. But specifically excluded from the benefits are uniformed personnel of the enumeration. In the present case, and for reasons already mentioned, there has been no such omission. There has only
AFP including those of the PC-INP. It can be argued that, expressio unius est exclusio alterius but the applicable maxim been a substitution of terms. On law reason and public policy, defendant-appellee’s contention that justices of the peace
in this case is the doctrine of necessary implication which holds that “what is implied in a statute is as much a part thereof are not covered by the injunction of Section 54 must be rejected. To accept it is to render ineffective a policy so clearly
as that which is expressed”. and emphatically laid down by the legislature.

[T]he Court believes, and so holds, that the denial by the respondents NIA and CSC of petitioner’s application for early Although it was observed that both the Court of Appeals and the trial court applied the rule of “expressio unius, est
retirement benefits under R.A. No. 6683 is unreasonable, unjustified, and oppressive, as petitioner had filed an exclusion alterius” in arriving at the conclusion that justices of the peace are not covered by Section 54, the rule has no
application for voluntary retirement within a reasonable period and she is entitled to the benefits of said law. In the application. If the legislature had intended to exclude a justice of the peace from the purview of Section 54, neither the
interest of substantial justice, her application must be granted; after all she served the government not only for two (2) trial court nor the Court of Appeals has given the reason for the exclusion. Indeed, there appears no reason for the alleged
years — the minimum requirement under the law but for almost fifteen (15) years in four (4) successive governmental change. Hence, the rule of expressio unius est exclusion alterius has been erroneously applied.
projects.
JM Tuason and Co. Inc. et. al. vs. Mariano et. al. [G.R. No. L-33140. October 23, 1978]
Manuel de Guia vs. COMELEC [G.R. No. 104712. May 06, 1992]
FACTS: The case began when Manuela Aquial and Maria Aquial filed a complaint in forma pauperis in the Court of First
FACTS: [C]ongress passed R.A. 7166, signed into law by the President on November 26, 1991. It is “An Act Providing for Instance of Rizal Pasig Branch X, wherein they prayed that they be declared the owners of a parcel of land located at
Synchronized National and Local Elections and for Electoral Reforms, Authorizing Appropriations Therefor, and for Balara, Marikina, Rizal, docketed as Civil Case No. 8943. They alleged that sometime in 1960, or after J. M. Tuason & Co.,
Other Purposes.” Respondent Commission on Elections (COMELEC) issued Resolution No. 2313, adopting rules and Inc. had illegally entered upon that land, they discovered that it had been fraudulently or erroneously included in OCT
guidelines in the apportionment, by district, of the number of elective members of the Sangguniang Panlalawigan in No. 735 of the Registry of Deeds of Rizal. They further alleged that transfer certificates of title, derived from OCT No.
provinces with only one (1) legislative district and the Sangguniang Bayan of municipalities in the Metro Manila Area 735, were issued to J. M. Tuason & Co., Inc., et.al. J.M. Tuason & Co., Inc. filed a motion to dismiss on the grounds of lack
for the preparation of the Project of District Apportionment by the Provincial Election Supervisors and Election of jurisdiction, improper venue, prescription, laches and prior judgment. The plaintiffs opposed that motion. The lower
Registrars, Resolution No. 2379, approving the Project of District Apportionment submitted pursuant to Resolution No. court denied it. The grounds of the motion to dismiss were pleaded as affirmative defenses in the answer of Tuason and
2313, and Resolution UND. 92-010 holding that pars. (a), (b) and (c), and the first sentence of par. (d), all of Sec. 3, R.A. J. M. Tuason & Co., Inc. They insisted that a preliminary hearing be held on those defenses. The Tuason and J. M. Tuason
7166, apply to the May 11, 1992 elections. Petitioner imputes grave abuse of discretion to COMELEC in promulgating the & Co., Inc. filed the instant civil actions of certiorari and prohibition praying, inter alia, that the trial court be ordered to
aforementioned resolutions, and maintained that election of Sanggunian members be “at large” instead of “by district”. dismiss the complaint and enjoined from proceeding in the said case, and a writ of preliminary injunction was issued.

ISSUE: Whether or not the petitioner’s interpretation of Sec.3 of R.A. 7166 is correct in assailing the aforementioned ISSUE: Whether or not OCT No. 735 and the titles derived therefrom can be questioned at this late hour by respondents
COMELEC Resolutions. Aquial and Cordova.

HELD: NO. Petition was dismissed for lack of merit HELD: NO. The trial court was directed to dismiss Civil Case 8943 with prejudice and without costs.
RATIO: Spirit and purpose of the law – The reason for the promulgation of R.A. 7166 is shown in the explanatory note
RATIO: Considering the governing principle of stare decisis et non quieta movere (follow past precedents and do not
of Senate Bill No. 1861, and that respondent COMELEC is cognizant of its legislative intent.No law is ever enacted that
disturb what has been settled), respondents Aquial and Cordova cannot maintain their action in Civil Case No. 8943
is intended to be meaningless, much less inutile. We must therefore, as far as we can, divine its meaning, its significance,
without eroding the long settled holding of the courts that OCT No. 735 is valid and no longer open to attack.It is against
its reason for being. As it has oft been held, the key to open the door to what the legislature intended which is vaguely
public policy that matters already decided on the merits be relitigated again and again, consuming the court’s time and
expressed in the language of a statute is its purpose or the reason which induced it to enact the statute.
energies at the expense of other litigants.
The true import of Par. (d) is that Sangguniang Panlungsod of the single-district cities and the Sangguniang Bayan of
the municipalities outside Metro Manila, which remained single-districts not having been ordered apportioned under