INTRINSIC AIDS

Text of the Statute as intrinsic aid

LIM V PACQUING
The text of RA 954 does not intimate that it is repealing any existing law, especially Sec 18 of RA 409. RA
954 has no repealing provision and the reason is obvious – it simply prohibited certain practices in jai-
alai then still unregulated by the laws of the land. It did not regulate aspects of jai alai already regulated
by existing laws, like the matter of whether it is the national government alone that should issue
franchise to operate jai alai games.
Note: Although this is a dissenting opinion, nevertheless it is persuasive and to stress the point that title
and text of the statute is a valuable intrinsic aid in determining legislative intent.

Subtitle of the statute as intrinsic aid in determining legislative intent

DEFENSOR SANTIAGO V COMELEC

While the Act provides subtitles for National Initiative and Referendum (Subtitle II) and for Local
Initiative and Referendum (Subtitle III), no subtitle is provided for initiative on the Constitution. This
conspicuous silence as to the latter simply means that the main thrust of the Act is initiative and
referendum on national and local laws. If Congress intended R.A. No. 6735 to fully provide for the
implementation of the initiative on amendments to the Constitution, it could have provided for a
subtitle therefor, considering that in the order of things, the primacy of interest, or hierarchy of values,
the right of the people to directly propose amendments to the Constitution is far more important than
the initiative on national and local laws.

Preamble as Intrinsic Aid

EUGENIO V EXECUTIVE SECRETARY

We hold otherwise, and herewith rule that respondent Executive Secretary did not abuse his discretion,
and that P.D. 957 is to be given retroactive effect so as to cover even those contracts executed prior to
its enactment in 1976.

P.D. 957 did not expressly provide for retroactivity in its entirety, but such can be plainly inferred from
the unmistakable intent of the law.

The intent of the law, as culled from its preamble and from the situation, circumstances and conditions
it sought to remedy, must be enforced. On this point, a leading authority on statutory construction
stressed:

The intent of a statute is the law x x x. The intent is the vital part, the essence of the law, and the
primary rule of construction is to ascertain and give effect to the intent. The intention of the legislature
in enacting a law is the law itself and must be enforced when ascertained, although it may not be
consistent with the strict letter of the statute. Courts will not follow the letter of a statute when it leads
away from the true intent and purpose of the legislature and to conclusions inconsistent with the
general purpose of the act x x x. In construing statutes the proper course is to start out and follow the
true intent of the legislature and to adopt that sense which harmonizes best with the context and
promotes in the fullest manner the apparent policy and objects of the legislature.1 (italics supplied.)
It goes without saying that, as an instrument of social justice, the law must favor the weak and the
disadvantaged, including, in this instance, small lot buyers and aspiring homeowners. P.D. 957 was
enacted with no other end in view than to provide a protective mantle over helpless citizens who may
fall prey to the manipulations and machinations of unscrupulous subdivision and condominium sellers,
and such intent is nowhere expressed more clearly than in its preamble, pertinent portions of which
read as follows: ()
From a dedicated reading of the preamble, it is manifest and unarguable that the legislative intent must
have been to remedy the alarming situation by having P.D. 957 operate retrospectively even upon
contracts already in existence at the time of its enactment. Indeed, a strictly prospective application of
the statute will effectively emasculate it, for then the State will not be able to exercise its regulatory
functions and curb fraudulent schemes and practices perpetrated under or in connection with those
contracts and transactions which happen to have been entered into prior to P.D. 957, despite obvious
prejudice to the very subdivision lot buyers sought to be protected by said law. It is hardly conceivable
that the legislative authority intended to permit such a loophole to remain and continue to be a source
of misery for subdivision lot buyers well into the future.

Adding force to the arguments for the retroactivity of P.D. 957 as a whole are certain of its provisions,
viz., Sections 20, 21 and 23 thereof, which by their very terms have retroactive effect and will impact
upon even those contracts and transactions entered into prior to P.D. 957s enactment:

PEOPLE V ECHAVEZ
We hold that the lower court correctly ruled that the decree does not apply to pasture lands because its
preamble shows that it was intended to apply to squatting in urban communities or more particularly to
illegal constructions in squatter areas made by well-to-do individuals. The squating complained of
involves pasture lands in rural areas.

The rule of ejusdem generis (of the same kind or species) invoked by the trial court does not apply to
this case. Here, the intent of the decree is unmistakable. It is intended to apply only to urban
communities, particularly to illegal constructions. The rule of ejusdem generis is merely a tool of
statutory construction which is resorted to when the legislative intent is uncertain (Genato Commercial
Corp. vs. Court of Tax Appeals, 104 Phil. 615,618; 28 C.J.S. 1049-50).

(Title)
CITY OF BAGUIO V MARCOS
It should be certain by now that when engaged in the task of construing an obscure expression in the
law 18 or where exact or literal rendering of the words would not carry out the legislative intent, 19 the
title thereof may be resorted to in the ascertainment of congressional will. Reason therefor is that the
title of the law may properly be regarded as an index of or clue or guide to legislative intention. 20 This
is especially true in this jurisdiction. For the reason that by specific constitutional precept, "[n]o bill
which may be enacted into law shall embrace more than one subject which shall be expressed in the
title of the bill." 21 In such case, courts "are compelled by the Constitution to consider both the body
and the title in order to arrive at the legislative intention." 22

With the foregoing guideposts on hand, let us go back to the situation that confronts us. We take
another look at the title of R.A. 931, viz: "AN ACT TO AUTHORIZE THE FILING IN THE PROPER COURT,
UNDER CERTAIN CONDITIONS, OF CERTAIN CLAIMS OF TITLE TO PARCELS OF LAND THAT HAVE BEEN
DECLARED PUBLIC LAND, BY VIRTUE OF JUDICIAL DECISIONS RENDERED WITHIN THE FORTY YEARS NEXT
PRECEDING THE APPROVAL OF THIS ACT." Readily to be noted is that the title is not merely composed of
catchwords. 23 It expresses in language clear the very substance of the law itself. From this, it is easy to
see that Congress intended to give some effect to the title of R.A. 931.

To be carefully noted is that the same imperfection in the language of R.A. 931 aforesaid — from which
surfaces a seeming inconsistency between the title and the body — attended Commonwealth Act 276,
the present statute's predecessor. That prior law used the very same language in the body thereof and
in its title. We attach meaning to this circumstance. Had the legislature meant to shake off any legal
effects that the title of the statute might have, it had a chance to do so in the reenactment of the law.
Congress could have altered with great facility the wording of the title of R.A. 931. The fact is that it did
not.

It has been observed that "in modern practice the title is adopted by the Legislature, more thoroughly
read than the act itself, and in many states is the subject of constitutional regulation." 24 The
constitutional in jurisdiction that the subject of the statute must be expressed in the title of the bill,
breathes the spirit of command because "the Constitution does not exact of Congress the obligation to
read during its deliberations the entire text of the bill." 25 Reliance, therefore, may be placed on the
title of a bill, which, while not an enacting part, no doubt "is in some sort a part of the act, although only
a formal part." 26 These considerations are all the more valid here because R.A. 931 was passed without
benefit of congressional debate in the House from which it originated as House Bill 1410, 27 and in the
Senate. 28

effects intended by legislation.

The sum of all the foregoing is that, as we now view Republic Act 931, claims of title that may be filed
thereunder embrace those parcels of land that have been declared public land "by virtue of judicial
decisions rendered within the forty years next preceding the approval of this Act." Therefore, by that
statute, the July 25, 1961 petition of respondent Belong Lutes to reopen Civil Reservation Case No. 1,
GLRO Record No. 211 of the cadastral court of Baguio, the decision on which was rendered on
November 13, 1922, comes within the 40-year period.

EXTRINSIC AIDS

DEFENSOR SANTIAGO V COMELEC

History of enactment, reasons for the passage of the bill and purposes to be accomplished by the
measure
COMMISSIONER OF CUSTOMS V ESSO
It is a well accepted principle that where a statute is ambiguous, as Republic Act No. 1394 appears to be,
courts may examine both the printed pages of the published Act as well as those extrinsic matters that
may aid in construing the meaning of the statute, such as the history of its enactment, the reasons for
the passage of the bill and purposes to be accomplished by the measure. 10

In order to determine the true intent of the legislature, the particular clauses and phrases of the statute
should not be taken as detached and isolated expressions, but the whole and every part thereof must be
considered in fixing the meaning of any of its parts. In fact every statute should receive such
construction as will make it harmonize with the pre-existing body of laws. Antagonism between the Act
to be interpreted and existing or previous laws is to be avoided, unless it was clearly the intention of the
legislature that such antagonism should arise and one amends or repeals the other, either expressly or
by implication.

Another rule applied by this Court is that the courts may take judicial notice of the origin and history of
the statutes which they are called upon to construe and administer, and of facts which affect their
derivation, validity and operation. 12

Applying the above stated rules and principles, let us consider the history, the purpose and objectives of
Republic Act No. 387 as it relates to Republic Act No. 1394 and other laws passed by the Congress of the
Philippines insofar as they relate to each other.
The title of Republic Act No. 387 and the provisions of its three articles just cited give a clue to the intent
of the Philippine legislature, which is to encourage the exploitation and development of the petroleum
resources of the country. Through the instrumentality of said law, it declared in no uncertain terms that
the intensification of the exploration for petroleum must be carried on unflinchingly even if, for the time
being, no taxes, both national and local, may be collected from the industry. This is the unequivocal
intention of the Philippine Congress when the language of the Petroleum Act is examined. Until this law
or any substantial portion thereof is clearly amended or repealed by subsequent statutes, the intention
of the legislature must be upheld.

Against this unambiguous language of R.A. No. 387, there is the subsequent legislation, R.A. No. 1394,
the Special Import Tax Law, which, according to the herein petitioner, shows that the legislature
considered the special import tax as a tax distinct from customs duties.
The title indicates unmistakably that it is repealing six prior statutes. As will be seen later, all these laws
dealt with the imposition of a special excise tax on foreign exchange or other form of levy on
importation of goods into the country.

As can be seen from the foregoing, in one fell swoop, Republic Act No. 1394 repealed and revoked six
earlier statutes which had something to do with the imposition of special levies and/or exemption of
certain importations from the burden of the special import taxes or levies. On the other hand, it is
apparent that R.A. No. 387, the Petroleum Act, had been spared from the pruning knife of Congress,
although this latter law had granted more concessions and tax exemption privileges than any of the
statutes that were amended, repealed or revoked by R.A. No. 1394. The answer must be that the
Congress of the Philippine saw fit to preserve the privileges granted under the Petroleum Law of 1949 in
order to keep the door open to the exploitation and development of the petroleum resources of the
country with such incentives as are given under that law.

This ascertained will and intention of the legislature finds a parallelism in a case brought earlier before
this Court.

Having this in mind, particularly the manner in which extrinsic aids the history of the enactment of the
statute and purpose of the legislature in employing a clause or provision in the law had been applied in
determining the true intent of the lawmaking body, We are convinced that R.A. No. 387, The Petroleum
Act of 1949, was intended to encourage the exploitation, exploration and development of the
petroleum resources of the country by giving it the necessary incentive in the form of tax exemptions.
This is the raison d etre for the generous grant of tax exemptions to those who would invest their
financial resources towards the achievement of this national economic goal.

Opinions and rulings of official of government

VERA V CUEVAS
Skimmed milk is different from filled milk. According to the "Definitions, Standards of Purity, Rules and
Regulations of the Board of Food Inspection," skimmed milk is milk in whatever form from which the
fatty part has been removed. Filled milk, on the other hand, is any milk, whether or not condensed,
evaporated concentrated, powdered, dried, dessicated, to which has been added or which has been
blended or compounded with any fat or oil other than milk fat so that the resulting product is an
imitation or semblance of milk cream or skim milk." The difference, therefore, between skimmed milk
and filled milk is that in the former, the fatty part has been removed while in the latter, the fatty part is
likewise removed but is substituted with refined coconut oil or corn oil or both. It cannot then be readily
or safely assumed that Section 169 applies both to skimmed milk and filled milk.

The Board of Food Inspection way back in 1961 rendered an opinion that filled milk does not come
within the purview of Section 169, it being a product distinct from those specified in the said Section
since the removed fat portion of the milk has been replaced with coconut oil and Vitamins A and D as
fortifying substances (p. 58, Rollo). This opinion bolsters the Court's stand as to its interpretation of the
scope of Section 169. Opinions and rulings of officials of the government called upon to execute or
implement administrative laws command much respect and weight. (Asturias Sugar Central Inc. vs.
Commissioner of Customs, G. R. No. L-19337, September 30, 1969, 29 SCRA 617; Tan, et. al. vs. The
Municipality of Pagbilao et. al., L-14264, April 30, 1963, 7 SCRA 887; Grapilon vs. Municipal Council of
Carigara L-12347, May 30, 1961, 2 SCRA 103).

ASTURIAS SUGAR V COMMISSIONER OF CUSTOMS

t would seem then that the Government would forego collecting duties on the articles mentioned in
section 105(x) of Tariff and Customs Code as long as it is assured, by the filing of a bond, that the same
shall be exported within the relatively short period of one year from the date of acceptance of the
import entry. Where an importer cannot provide such assurance, then the Government, under sec.
106(b) of said Code, would require payment of the corresponding duties first. The basic purpose of the
two provisions is the same, which is, to enable a local manufacturer to compete in foreign markets, by
relieving him of the disadvantages resulting from having to pay duties on imported merchandise,
thereby building up export trade and encouraging manufacture in the country. 12 But there is a
difference, and it is this: under section 105(x) full exemption is granted to an importer who justifies the
grant of exemption by exporting within one-year. The petitioner, having opted to take advantage of the
provisions of section 105(x), may not, after having failed to comply with the conditions imposed thereby,
avoid the consequences of such failure by being allowed a drawback under section 106(b) of the same
Act without having complied with the conditions of the latter section.

For it is not to be supposed that the legislature had intended to defeat compliance with the terms of
section 105(x) thru a refuge under the provisions of section 106(b). A construction should be avoided
which affords an opportunity to defeat compliance with the terms of a statute. 13 Rather courts should
proceed on the theory that parts of a statute may be harmonized and reconciled with each other.

A construction of a statute which creates an inconsistency should be avoided when a reasonable

interpretation can be adopted which will not do violence to the plain words of the act and will carry out
the intention of Congress.

In the construction of statutes, the courts start with the assumption that the legislature intended to
enact an effective law, and the legislature is not to be presumed to have done a vain thing in the
enactment of a statute. Hence, it is a general principle, embodied in the maxim, "ut res magis valeat
quam pereat," that the courts should, if reasonably possible to do so without violence to the spirit and
language of an act, so interpret the statute to give it efficient operation and effect as a whole. An
interpretation should, if possible, be avoided under which a statute or provision being construed is
defeated, or as otherwise expressed, nullified, destroyed, emasculated, repealed, explained away, or
rendered insignificant, meaningless, inoperative, or nugatory. 14

Legislative deliberations
NAPOLCOM V JUDGE DE GUZMAN
From a careful perusal of the above provisions, it appears therefore that the use of the term INP is not
synonymous with the PC. Had it been otherwise, the statute could have just made a uniform reference
to the members of the whole Philippine National Police (PNP) for retirement purposes and not just the
INP. The law itself distinguishes INP from the PC and it cannot be construed that "INP" as used in Sec. 89
includes the members of the PC.
Having defined the meaning of INP, the trial court need not have belabored on the supposed dubious
meaning of the term. Nonetheless, if confronted with such a situation, courts are not without recourse
in determining the construction of the statute with doubtful meaning for they may avail themselves of
the actual proceedings of the legislative body. In case of doubt as to what a provision of a statute
means, the meaning put to the provision during the legislative deliberations may be adopted (De Villa v.
Court of Appeals,
195 SCRA 722 [1991] citing Palanca v. City of Manila, 41 Phil. 125 [1920]; Arenas v. City of San Carlos, 82
SCRA 318 [1978]).

Courts should not give a literal interpretation to the letter of the law if it runs counter to the legislative
intent (Yellow Taxi and Pasay Transportation Workers' Association v. Manila Yellow Taxi Cab. Co., 80
Phil. 83 [1948]).

Examining the records of the Bicameral Conference Committee, we find that the legislature did intent to
exclude the members of the PC from the coverage of Sec. 89 insofar as the retirement age is concerned,
thus:

In applying the provisions of Sec. 89 in favor of the local police force as established in PD 765, the Court
does not, in any manner, give any
undue preferential treatment in favor of the other group. On the contrary, the Court is merely giving life
to the real intent of the legislators based on the deliberations of the Bicameral Conference Committee
that preceded the enactment of RA 6975.

Individual statements by members of the Congress on the floor do not necessarily reflect legislative
intent
CASCO V GIMENEZ
Petitioner maintains that the term "urea formaldehyde" appearing in this provision should be construed
as "urea and formaldehyde" (emphasis supplied) and that respondents herein, the Auditor General and
the Auditor of the Central Bank, have erred in holding otherwise. In this connection, it should be noted
that, whereas "urea" and "formaldehyde" are the principal raw materials in the manufacture of
synthetic resin glues, the National Institute of Science and Technology has expressed, through its
Commissioner, the view that:

Urea formaldehyde is not a chemical solution. It is the synthetic resin formed as a condensation product
from definite proportions of urea and formaldehyde under certain conditions relating to temperature,
acidity, and time of reaction. This produce when applied in water solution and extended with
inexpensive fillers constitutes a fairly low cost adhesive for use in the manufacture of plywood.

Hence, "urea formaldehyde" is clearly a finished product, which is patently distinct and different from
urea" and "formaldehyde", as separate articles used in the manufacture of the synthetic resin known as
"urea formaldehyde". Petitioner contends, however, that the bill approved in Congress contained the
copulative conjunction "and" between the terms "urea" and "formaldehyde", and that the members of
Congress intended to exempt "urea" and "formaldehyde" separately as essential elements in the
manufacture of the synthetic resin glue called "urea" formaldehyde", not the latter as a finished
product, citing in support of this view the statements made on the floor of the Senate, during the
consideration of the bill before said House, by members thereof. But, said individual statements do not
necessarily reflect the view of the Senate. Much less do they indicate the intent of the House of
Representatives (see Song Kiat Chocolate Factory vs. Central Bank, 54 Off. Gaz., 615; Mayon Motors Inc.
vs. Acting Commissioner of Internal Revenue, L-15000 [March 29, 1961]; Manila Jockey Club, Inc. vs.
Games & Amusement Board, L-12727 [February 29, 1960]). Furthermore, it is well settled that the
enrolled bill — which uses the term "urea formaldehyde" instead of "urea and formaldehyde" — is
conclusive upon the courts as regards the tenor of the measure passed by Congress and approved by
the President (Primicias vs. Paredes, 61 Phil. 118, 120; Mabanag vs. Lopez Vito, 78 Phil. 1; Macias vs.
Comm. on Elections, L-18684, September 14, 1961). If there has been any mistake in the printing ofthe
bill before it was certified by the officers of Congress and approved by the Executive — on which we
cannot speculate, without jeopardizing the principle of separation of powers and undermining one of
the cornerstones of our democratic system — the remedy is by amendment or curative legislation, not
by judicial decree.

KILOSBAYAN V MORATO