Chapter IV-ALiteral Interpretation

1. Kapisanan ng mga Manggagawa sa Manila Railroad Company vs. Manila Railroad CompanyG.R. No. L-25316, Feb. 28, 1979

FACTS:Petitioner-appellant would seek a reversal of the mandamus petition dismissed by the lower court relying on what it considered to be a right granted by Section 62 of the Republic Act No. 2023, more specifically on the collection/ deduction of the employer from the salary or wages of its employee in satisfaction of any debt or other demand owing from the member to the co-operative and that the employer is required by the co-operative by a request in writing and if any debt or other demand or any part of it remains unpaid, make the claimant and remit forth with the amount so deducted to the co-operative.

Petitioner contends that under the above provisions of Rep. Act 2023, the loans granted by credit union to its members enjoy first priority in the payroll collection from the respondent's employees' wages and salaries.Court ruled in favor of respondent and held that: there is nothing in the provision of Rep. Act 2023 herein above quoted which provides that obligation of laborers and employees payable to credit unions shall enjoy first priority in the deduction from the employees' wages and salaries.The only effect of Rep. Act 2023 is to compel the employer to deduct from the salaries or wages payable to members of the employees' cooperative credit unions the employees' debts to the union and to pay the same to the credit union. If Rep. Act 2023 had been enacted, the employer could not be compelled to act as the collecting agent of the employees' credit union for the employees' debt to his credit union but to contend that the debt of a member of the employees cooperative credit union as having first priority in the matter of deduction, is to write something into the law which does not appear. The mandatory character to compel employer to make deduction of the employees debt does not convert the credit union's credit into a first priority credit. If such is the legislative intent in enacting pars. 1 and 2 of Sec. 62 of Rep. Act 2023, the law would have so expressly declared. Thus, the express provisions of the New Civil Code, Arts. 2241, 2242 and 2244 show the legislative intent on preference of credits. ISSUE: WON the petitioners interpretation of RA 2023 is correct?HELD: NO That there is nothing in said provision from which it could be implied that it gives top priority to obligations of the nature of that payable to petitioner, and that, therefore, respondent company did not violate the above-quoted Section 62 of Republic Act 2023.

The applicable provision of Republic Act No. 2023 quoted earlier, speaks for itself. There is no ambiguity.

Petitioner-appellant cannot therefore raise any valid objection. For the lower court to view it otherwise would have been to alter the law. That cannot be done by the judiciary. That is a function that properly appertains to the legislative branch. As was pointed out inGonzaga v. Court of Appeals:"It has been repeated time and time again that where the statutory norm speaks unequivocally, there is nothing for the courts to do except to apply it. The law, leaving no doubt as to the scope of its operation, must be obeyed. Our decisions have consistently born to that effect.

2. Abellana vs. Marave, G.R. No. L-27760, May 29, 1974

FACTS:Abellana while driving his cargo truck hittinga motorized pedicab resulting ininjuries to itspassengers, private respondents, Lamason, Gurrea, Flores, Nemeno resulting in the crime of physical injuries thru reckless imprudence.

RTC of Ozamis found Abellan guilty of thesaid crime in the criminal case, damages was in favorawarded to the offendedparties. Abellana appealed this decision. Likewise, the offended parties filed aseparate and independent civil action for damages allegedly suffered by them forreckless driving of Abellana. Crispin Abellana, as employer of Francisco was included asdefendants in the complaint.

Both Crispin and Francisco sought the dismissal of such action principally on the ground that there was no reservation for the filing thereof inthe City Court ofOzamis invoking the Rules of Court provision to the effect that upon the institution of a criminal action the civil action for recovery of civil liability arising from the offense charge is impliedly instituted with the criminal action, unless the offended partyreserves or waives his right to institute it separately.. They argued it was not allowable at the stage where the criminal case was already on appeal. ISSUE: Whether or not petitioners interpretation of Sec. 1 Rule 111 is correct. HELD:No, the conclusion of the respondent that absent such a reservation, an independent civil action is barred is incorrect. Such an inference does not per se arise from thewording of the cited rule. The restrictive interpretation on the part of the petitioner as they would place on the applicable rule does not only result in its emasculation but also gives rise to a serious constitutional question. Article 33 of the Civil Code is quite clear: In cases ofphysical injuries, a civil action for damages, entirely separate and distinct from the criminal action, may be brought by the injured party. Such civil action shall proceed independently of the criminal prosecution, and shall require only preponderance of evidence.The Supreme Court averred the preceding provision of Civil Code is a SUBSTANTIAL RIGHT, not to be frittered away by a construction that can render it nugatory, if through oversight, the offended parties failed at the initial stage to seek recovery for damages in a civil suit. The grant of power to the Supreme Court, both in the present Constitution and under the 1935 Constitution does not extended to any diminution, increase or modification of substantive right. It is a well-settled doctrine that a court is to avoid construing a statute or legal norm in such a manner as would giverise to aconstitutional doubt.The elementary rule in statutory construction is that when the words and phrases of the statute are clear and unequivocal, their meaning must be determined from the language employed and the statute must be taken to mean what it says. Hence, what is not clearly provided in the law cannot be extended to those matters outside its scope.

3. Paras vs. Commission on ElectionG.R. No. 123169, Nov. 4, 1996

Dura Lex Sed Lex People of the Philippines vs. Macarandang, G.R. No. L-12088, Dec. 23, 1959 People of the Philippines vs. Mapa, G.R. No. L-22301, Aug. 30, 1967 People of the Philippines vs. Santayana, G.R. No. L-22291, Nov. 15, 1976

Chapter IV-BDeparture from Literal Interpretation King vs. Hernandez, 114 Phil. 730 United States vs. Toribio, 15 Phil. 85 Amatan vs. Aujero, 248 SCRA 511 People of the Philippines vs. Purisima, G.R. No. 42050, Nov. 20, 1978 Salvacion vs. Central Bank, 278 SCRA 27

Chapter IV-CImplications Commission on Audit vs. Province of Cebu, G.R. No. 141386, Nov. 29, 2001 Batungbakal vs. National Development Co., 93 Phil. 18 GSIS vs. Civil Service Commission, 202 SCRA 799