STATUTORY CONSTRUCTION
A.Y. 1819– ATTY. ALIMURUNG
TOPIC Interpretation of Penal Laws
CASE NO. G.R. No. L-12891 (1917)
CASE NAME The United States v. Filomeno Estapia et al
PONENTE Carson
PETITIONER The United States represented by Acting
Attorney-General
RESPONDENT Filomeno Estapia et al.
TYPE OF Appeal
CASE
MEMBER Lead Dampil
Get ready, the case is jampacked with StatCon rules.
ISSUE
1. W/N Estapia and his friends are in violation of Act 480? (No)
RELEVANT FACTS:
1.) The police caught Estapia and his friends taking part in an
Ihaway (ihaw + away? lol), either as a principal or a spectator,
in a ring beneath a buri palm near a recently constructed house
a. it’s a type of cockfight where the losing cock will be
eaten by the two competing cock-owners
2.) BUT nothing else on the record would tend to show that:
a. the ring beneath a buri palm had ever been used for
cockfighting on any other time; or
b. at that time, more than one cockfight took place; or
c. that any wager or bet was made on the fight (other than
that the losing cock will be eaten)
3.) NEVERTHELESS, proof of these facts judgment was entered
in the court below convicting the defendants of a violation of
Act No. 480. The pertinent provisions state:
Section 1: (special arrangement mine)
any person who shall:
a. maintain a cockpit for the fighting of cocks, or
b. engage in cockfighting in a cockpit, or
c. attend as a spectator of cockfighting in a cockpit,
on any day when cockfighting is not lawfully licensed to take place
by the municipality in which the cockpit is situate, shall be punished
Section 2: (special arrangement mine)
any person who shall:
a. maintain or take in a game of chance in a cockpit,
whether the cockpit be lawfully licensed or not, shall be punished
Argument of the Attorney-General:
A “cockpit” is any place where a cockfight takes place, as it’s
also had always been construed by the Collector of Internal
Revenue.
RATIO DECIDENDI
1. NO, Estapia and his friends are not in violation of Act No. 480.
1ST RULE: Ut Res Magis Valeat Quam Pereat (all the words of a
statute are to be given some meaning so that when the
legislator makes use of words of limitation, he must be
presumed to have intended to limit and restrict the word or idea
with reference to which such words of limitation applied)
APPLICATION: All prohibitions on cockfighting is qualified by the
phrase “in a cockpit.” If cockfighting means exactly the same
thing as “cockfighting in a cockpit”, then why would the
legislator even bother stating the latter rather than the former?
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 STATUTORY CONSTRUCTION
A.Y. 1819– ATTY. ALIMURUNG
2ND RULE: Penal Provisions of a Statute are Construed Strictly – It
can’t be construed that when the legislator penalizes the
commission of an act on certain specific occasions, he
intends to penalize it on all occasions.
APPLICATION: To hold that the Act penalized unlicensed cockfighting
on all occasions and wherever it may take place, despite the
fact that these particular penalties are especially limited to
unlicensed cockfighting in a cockpit, would run counter to
both the spirit and the letter of this rule.
Note: the first two rules were made to prove that the qualifying term
“cockpit” must be given effect. Now, the court will try to construe
what “cockpit” actually means.
3RD RULE: Noscitur A Sociis – where a particular word or term is
ambiguous in itself, its correct construction may be made clear
and specific by considering the company of words in which it is
found or with which it is associated.
APPLICATION: The provisions concerning the maintenance of the
cockpit [see Sec. 1(a), and Sec. 2(a)] clearly indicates that the
legislator intended the word “cockpit” to be understood as some
place:
a.) especially designed for use by cockfighters, or
b.) which upon a single occasion, and without special
preparation, a single encounter takes place between the birds.
SUPPORT:
Plain Meaning Rule
A “cockpit: is commonly and popularly understood (by culture
and dictionaries) to mean any place especially designed for
use by the cockfighters for frequent use.
Spanish Definition Rule (Special for the Philippines)
Although where a statute is promulgated in English and
Spanish, the English shall govern, the Spanish may be
consulted to explain the English text in case of ambiguity. The
equivalent Spanish word gallera conveys a stricter idea of a
place specially and expressly designed for the conduct of
cockfighting.
IN THIS CASE: nothing on the record would tend to show that
the ring under the buri palm had ever been used for cockfighting
on any other time; or that at least no preparations were
especially made by the owners of a couple of birds betake
themselves on a single occasion for a single encounter.
4TH RULE: An Administrative or Executive Interpretation of a
statute shall be given high persuasive value in matters
concerning the expertise of that department or agency.
APPLICATION: Although the Collector of Internal Revenue, has
always construed a “cockpit” as any place where a cockfight
takes place, Act No. 480 is a Penal Statute – not a
Revenue Statute. Thus the CIR’s construction can’t apply.
MOREOVER: “In view of the penal character of the statute, the
courts should not be convinced by any construction placed
upon it by the executive officers of the government, even if the
language were fairly susceptible of the meaning place upon it
by those officers.”
DISPOSITIVE POSITION
WHEREFORE, the judgment appealed from should be REVERSED,
and the accused acquitted of the offense of which they were convicted.
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 STATUTORY CONSTRUCTION
A.Y. 1819– ATTY. ALIMURUNG
Note: The main case never delved into how the prosecution had the
fatal mistake of failing to prove that a wager or bet was made during
the ihaway – which constitutes the element of “consideration” in the
game of chance. But the dissenting opinion briefly discusses it.

DISSENTING OPINION by MALCOLM

Main Idea:
The purpose of this section is absolutely to prohibit
cockfighting, except on certain specific days. Betting is not an
essential element of the offense. We should consider how the
executive department construes how a “cockpit” is understood.