Statutory Construction | Case Digests on Validity of Statutes

Case 1 IBP vs. Zamora G.R. No. 141284

1987 Constitution, the petitioners have established their cause of action. Hence, the licenses must be revoked and rescinded by executive action

Facts: IBP challenges the constitutionality of the issuance of President Estrada deploying the PNP and Marines in visibility patrols around the metropolis. IBP contends that there was no emergency situation in Metro Manila deeming it a need to deploy soldiers for law enforcement, and that the President has exercised power beyond the limits prescribed by the Constitution.

Case 3 Cuyegkeng vs. Cruz G.R. No. L-16263

Issue: Whether or not the President’s Issuance is constitutional Held: Yes. The Court dismissed the case on the grounds that petitioners, although have legal personality or locus standi due to the advancement of the issue they presented, failed to recognize the wisdom behind the power of the President to invoke the military as one of his rights for the basis of maintenance of peace order and for the avoidance of lawless violence. Case 2 Oposa vs. Factoran G.R. No. 101083 Facts: Petitioners, which consist of minors, represented by their parents, filed for a taxpayers’ suit, praying for the cancellation and cessation of all existing timber license agreements, and other processes regarding TLAs in the country as said TLAs affect the balance and health of ecology. Respondent contends that petitioners have no cause of action and that what they are presenting is a political question. Petitioners sought Articles 19-21 of the Civil Code, Sec. 4 of E.O. 192, Sec. 3 of P.D. 1151 and Sec. 16 of Article 2 of the 1987 Constitution as cause of action. While they also justified that their issue is of a justiciable question. Issue: Whether or not the petitioners have a cause of action Held: Yes. The Court ruled that the case is of common interest and importance to all Filipinos. By invoking Articles 19-21 of the Civil Code, Sec. 4 of E.O. 192, Sec. 3 of P.D. 1151 and Sec. 16 of Article 2 of the

Facts: Among the 12 nominees for the Board of Medical Examiners, only 6 were shortlisted by the President, which includes Dr. Pedro Cruz, a government physician. The petitioners, who are among the nominees cut by the president, prayed for two causes of action. The first, being that any one of them is qualified for the position and that Dr. Cruz’s appointment be rendered illegal, thus null and void. While the second, prays for a writ of preliminary injunction, ceasing, desisting and refraining the respondent from assuming and performing the role of Board Medical Examiner, and for the respondent to pay for the costs of this suit. The petition for preliminary injunction was dismissed. The Council of Philippine Medical Association, and incorporated association intervened enjoining the petitioners in their prayer for relief. Issue: Whether or not petitioners’ have valid causes of action. Held: No. The Court Ruled that Respondent has a good and valid right to his title on the grounds that one who does not claim to be entitled to the office allegedly usurped or unlawfully held or exercised by another cannot question his title by quo warranto. This suggests that petitioners have no cause of action against the respondent. While the intervenors have no right to question the title of respondent. Hence, the petition for quo warranto has no merit.

Case 4 Kilos Bayan vs. Morato G.R. No. 118910 Facts: A petition was filed to declare the Equipment Lease Agreement (ELA) between PCSO and PGMC invalid. Petitioner contends that ELA is similar to a Contract of Lease (COL) and that it violates PCSO’s charter as well as the law of Public Bidding, and Sec. 2(2) Art. 9 of the Constitution. Respondent contends that petitioners have no legal standing on the issue and that ELA is different from COL, and bidding is not a requirement. Respondent also said that petitioner has no legal standing. Issue: Whether or not petitioners have legal standing on the issue Held: No. Although in the previous case involving the petitioner sustaining their standing, the current case does not invoke stare decisis as no constitutional issue was actually involved. The Court ruled that they are two different cases since ELA is a different contract. The Court also said that it is not standing that should be considered, rather whether or not petitioners are really parties of interest. Case 5 Tijam vs. Sibonghanoy G.R. L-21450 Facts: Tijam filed for the recovery of Php 1908.00 with legal interest, which started from the day of filling of complaint until the completion of the obligation against Sibonghanoy. Although the trial was rendered in favor of plaintiffs, the writ of execution was returned unsatisfactory, so plaintiffs moved for the execution of Surety’s bond, which was granted. Surety moved to quash the writ but was denied. They now appealed to the CA on the grounds of lack of jurisdiction. However, CA affirmed the previous decision. Upon receipt of notice, Surety asked for an extension of time, which was granted. Two days later, Surety filed for a Motion to Dismiss on the grounds that CFI lacked jurisdiction in view of the effectivity of Judiciary Act of 1948 a month before plaintiffs filed for the petition for recovery. Case was then referred to the Supreme Court.

Issue: Whether or not Motion to Dismiss filed by Surety is valid on the grounds that it was raised the first time after decision has been rendered on the core issue Held: No. The Court ruled that Surety is now barred by laches from invoking the plea only after almost 15 years, having raised the issue on lack of jurisdiction only this time. It hs been held that after voluntarily submitting a cause and encountering an adverse decision on the merits, it is too late for the loser to question the jurisdiction of the court. Case 6 Zandueta vs. De la Costa G.R. No. L-46267 Facts: Zandueta has been discharged the office of judge of first instance in the Ninth Judicial District, 5th branch of the Court of First Instance by virtue of ad interim appointment issued by the President and confirmed by the Commission on appointments of the National Assembly. When Commonwealth Act No. 145 or the Judicial Reorganization Law took effect, he was given a new ad interim appointment as judge of first instance of the Fourth Judicial District, with authority to preside over the CFI of Manila and Palawan. A year after, he was assigned to another ad interim appointment to the same office, which he took an oath to but was later disapproved by the Secretary of Justice. Respondent De la Costa replaced Zandueta as appointed by the President and approved by Commission on Appointments. Zandueta questions the constitutionality of C.A. No. 145. Issue: Whether or not Zandueta may question the constitutionality of C.A. No. 145 Held: No. The Court ruled that Zandueta’s own act estopped him from questioning the constitutionality of C.A. No. 145. The Court opined that when a judge accepts another appointment, enters into the discharge of its functions and receives the corresponding salary, he abandons his old office and cannot claim to repossess it or question the constitutionality of the law by virtue of which his new appointment has been issued.

Case 8 Norton vs. Shelby 118 US 425 Facts: An action upon 29 bonds of $1000 each of Shelby County Tennessee, entitled Shelby County Railroad Bond No. 176, indebting the said county to Mississippi River Railroad for the subscription of $300 000 to said company, is made by county commissioners. The plaintiff contends that the commissioners are valid and lawful representatives of the county, of a de facto nature, and whose authority the county ratified. While the defendant says otherwise on the grounds that there exists no office of county commissioner, hence the nonexistence of de facto officers rendering the bonds null and void and there never was a ratification that took place. Issue: Whether or not County Commissioners of Shelby County are constitutional Held: No. The Court ruled there could be no officer, either de facto or de jure, if there is no office to fill. Since no ratification took place, the act creating the office commissioner never became a law hence it never existed. The bonds were rendered void, along with the County Commissioners of Shelby County. Case 9 Manila Motor vs. Flores G.R. No. L-9396 Facts: Manila Motor Company filed a complaint against Flores to recover the amount of Php 1047.98 as chattel mortgage installments which should have been paid 13 years ago. Since moratorium laws rendered the ten-year term still running plaintiffs appeal was considered by CFI. The defendant contends that moratorium laws have no effects, as they are unconstitutional Issue: Whether or not the moratorium laws are valid Held: Yes. By virtue of operative fact doctrine, the validity of the moratorium law is still exercised in this case, out of equity since the statute concerning moratorium laws have existed prior to the

declaration of their invalidity in Rutter vs. Esteban, and during the filing of this case. Case 10 Fernandez vs. Co G.R. L-21114 Facts: The plaintiff, a former of employee of the defendant, sought to claim the pay that was due him in a total amount of Php 11, 570.00. Although plaintiff filed his concern in the court three years after his resignation, his filing of a claim regarding said issue to the Regional Office of the Department of Labor suspended the prescriptive period, which was held at 8 months after his separation from the company. Issue: Whether or not the claim of the plaintiff is valid Held: Yes. The Court ruled that although Reorganization Plan No. 20-A was rendered unconstitutional now, it was however binding during the time the plaintiff sought the jurisdiction of the Department of Labor on his concern. Judicial power was present at that time and still applies as for the case at hand. Case 7 Ocampo vs. The Secretary of Justice G.R. No. L-7910 Facts: