Endencia vs. David Case Digest

PASTOR M. ENDENCIA and FERNANDO JUGO vs. SATURNINO DAVID, as Collector of Internal Revenue G.R. No. L-6355-56 August 31, 1953 ROCHE, CHRISTINE I.

Power to Construe as a Judicial Function

MONTEMAYOR, J.: FACTS: By virtue of Republic Act No. 590, Saturnino David, Collector of Internal Revenue, was able to collect payment for income taxes from Justice Endencia and Justice Jugo. However, the two Justices wanted to refund such payment because it had violated their privilege of being exempt from the collection of income tax by virtue of the Constitution under Section 9, Article VIII. Thus, they filed before the Supreme Court to declare Republic Act No. 590 unconstitutional. The passage of such law was because the Legislature could not accept the decision of the Supreme Court in the case of Perfecto vs. Meer; exempting the judicial officers to be taxed by the Collector of Internal Revenue. ISSUE: WON the Legislature can pass a law that would not exempt the judicial officers from paying income tax when in fact, as interpreted by the Supreme Court and decided in the Perfecto case, judicial officers are exempt from paying income tax. RULING: The power to interpret laws is vested to our Judiciary; whenever a statute is in violation of the fundamental law, the courts must adjudge and thereby give effect to the Constitution. What the Congress did was to interpret the meaning of the phrase “which shall not be diminished during their continuance in office” found in Section 9, Article VIII of the Constitution. The act of interpreting the Constitution or any part thereof by the Legislature is an invasion of the jurisdiction of the Judiciary. If the Legislature may declare what a law means, or what specific portion of the Constitution means, especially after the courts have in actual case ascertain its meaning by interpretation and applied it in a decision, this would surely cause confusion and instability in judicial processes and court decisions. Furthermore, the reason behind the exemption is to preserve the independence of the Judiciary.