03. 16 SCRA 379 (1966) Guevara v Inocentes

CASE DIGEST Topic II. CONSTRUCTION AND INTERPRETATION F. Power to construe 1. When is it proper to apply rules of statutory construction? Case Tile / Year of Decision Guevara vs. Inocentes, 16 SCRA 379 (1966) Facts On November 25, 1965, Onofre Guevara took his oath as an Undersecretary of Labor after his appointment was extended ad interim on November 22, 1965. The appointment was questioned by Rauol Inocentes on the ground that Guevara’s appointment ceases to be valid after each term of Congress. At around midnight of January 22, 1966, the Senate adjourned its session. The House of Representatives continued its session and adjourned upon learning the Senate’s adjournment. In the case of Guevara’s appointment, Congress, through the Commission on appointments has not acted on it while the special session is being conducted. Issue Whether the ad interim appointment of Onofre P. Guevara is valid. Held No. When the intention of the legislature is so apparent from the face of the statute that there can be no question as to its meaning, there is no room for construction. The ad interim appointment extended to Guevara on November 18, 1965 by the former Executive lapsed when the special session of congress adjourned sine die at about midnight of January 22, 1966.

III. Construction of Interpolation F. Power to Construe 1. When is it proper to apply rules of statutory construction? Title:

Guevarra vs. Inocentes, 16 SCRA 379 GR No. L-25577, 15 March 1966

Facts: Onofre p. Guevarra, petitioner, was extended an ad interim appointment as Undersecretary of Labor by outgoing President Diosdado Macapagal on 18 November 1965. Raoul M. Inocentes, respondent, was also extended an ad interim appointment for the same position by the then incumbent President Ferdinand Marcos on 23 January 1966. Petitioner Guevarra argued that his ad interim appointment was valid primarily because (1) the adjournment contemplated in Article Vii, Section 10 (4) of the 1935 Constitution should refer to “regular” session when the Commission on Appointments may be organized and allowed to discharge its functions, and not to the adjournment sine die of the “special” session made by the Senate at about midnight of 22 January 1966; and 92) there had been no adjournment of Congress as its “special” session was suspended by the House at 10:55 p.m. on 22 January 1966. Issue: Whether or not the ad interim appointment of the petitioner was valid. Held:

No. The Supreme Court resolved that the ad interim appointment extended to petitioner Guevarra on 18 November 1965 by the former Executive lapsed when the special session of Congress adjourned sine die at about midnight of 22 January 1966. The Supreme Court emphasized that “when the intention of the legislature is so apparent from the face of the statute (in this case Article VII, Section 10 (4) of the 1935 Constitution) that there can be no question as to its meaning there is no room for construction.” J. Concepcion in his concurring opinion cited the following American Jurisprudence:

xxx Where the language of a statute is plain and unambiguous and conveys a clear and definite meaning, there is no occasion for resorting to the rules of statutory construction, and the court has no right t look for or impose another meaning.” Petition denied. X-ref: Rodriguez vs. Quirino GR No. L-19800, 28 October 1953 Aytona vs. Castillo, et al. GR No. L-19313, 20 January 1962 sine die – “without day”; “final adjournment” ad interim – “constructive recess”