Noblejas v Teehankee

G.R. No. L-28790 April 29, 1968

Doctrine:
Statutes should be given, whenever possible, a meaning that will not bring them in conflict
with the Constitution.

Facts:
Antonio Noblejas was duly appointed Commissioner of Land Registration, a position
created by RA 1151. By the terms of section 2 of said Act, the said Commissioner is declared
"entitled to the same compensation, emoluments and privileges as those of a Judge of the Court
of First Instance."
In due course, Noblejas received a communication signed by the Executive Secretary
suspending him from office pending investigation of the charges on the alleged irregularities in
his official functions.
Noblejas contended he could only be suspended and investigated in the same manner as
a Judge of the Courts of First Instance, and, therefore, the papers relative to his case should be
submitted to the Supreme Court, for action thereon conformably to section 67 of the Judiciary
Act (R. A. No. 296) and Revised Rule 140 of the Rules of Court.

Issue:
Whether or not Noblejas could only be suspended and investigated in the same manner
as a Judge of the Courts of First Instance.

Ruling:
No. Section 67 of the Judiciary Act providing for investigation, suspension or removal of
Judges, specifically recites that "No District Judge shall be separated or removed from office by
the President of the Philippines unless sufficient cause shall exist in the judgment of the Supreme
Court." and it is nowhere claimed, much less shown, that the Commissioner of Land Registration
is a District Judge, or in fact a member of the Judiciary at all.
Petitioner's theory that the grant of "privileges of a Judge of First Instance" includes by
implication the right to be investigated only by the Supreme Court and to be suspended or
removed upon its recommendation, would necessarily result in the same right being possessed
by a variety of executive officials upon whom the Legislature had indiscriminately conferred the
same privileges. To adopt petitioner's theory, therefore, would mean placing upon the Supreme
Court the duty of investigating and disciplining all these officials, whose functions are plainly
executive, and the consequent curtailment by mere implication from the Legislative grant, of the
President's power to discipline and remove administrative officials who are presidential
appointees, and which the Constitution expressly placed under the President's supervision and
control.
Aznar v Yapdiangco
G.R. No. L-18536 March 31, 1965

Doctrine:
Contracts only constitute titles or rights to the transfer or acquisition of ownership, while
delivery or tradition is the method of accomplishing the same.

Facts:
Jose Aznar bought a car from Vicente Marella, which Marella acquired by fraud from
Teodoro Santos. Said car was seized and confiscated from Aznar by the Philippine Constabulary
in consequence of the report to them by Teodoro Santos that the said car was unlawfully taken
from him. Aznar ultimately argued that he acquired the car in good faith and for a valuable
consideration from Vicente Marella, and that was entitled to its recovery on the mandate of Article
1506 of the New Civil Code, and not Article 559 of the same law, which provides:

ART. 1506. Where the seller of goods has a voidable title thereto, but his, title has not
been voided at the time of the sale, the buyer acquires a good title to the goods, provided he buys
them in good faith, for value, and without notice of the seller's defect of title.

Issue:
Whether or not Jose Aznar has a better right over the car.

Ruling:
No. Under the aforequoted provision, it is essential that the seller should have a voidable
title at least. It is very clearly inapplicable where, as in this case, the seller had no title at all.
Vicente Marella did not have any title to the property under litigation because the same
was never delivered to him. He sought ownership or acquisition of it by virtue of the contract.
Vicente Marella could have acquired ownership or title to the subject matter thereof only by the
delivery or tradition of the car to him.
For the legal acquisition and transfer of ownership and other property rights, the thing
transferred must be delivered, inasmuch as, according to settled jurisprudence, the tradition of
the thing is a necessary and indispensable requisite in the acquisition of said ownership by virtue
of contract. So long as property is not delivered, the ownership over it is not transferred by
contract merely but by delivery. Contracts only constitute titles or rights to the transfer or
acquisition of ownership, while delivery or tradition is the method of accomplishing the same, the
title and the method of acquiring it being different in our law.
Laureano v CA
G.R. No. 114776 February 2, 2000

Doctrine:
Where two statutes are of equal theoretical application to a particular case, the one
designed therefore should prevail.

Facts:
Menandro Laureano was one of the pilots not qualified for promotion to one of the fleet
of Singapore Airlines Limited. His termination was mainly grounded on authorized cause when
Singapore Airlines needed to cost-cut to address the recession. Laureano questioned said
dismissal by filing a case for illegal dismissal before the Labor Arbiter on June 1983, but he
subsequently withdrawn the same. It was only on February 1987 when Laureano filed for
damages due to illegal termination of contract of services before the RTC. Singapore Airlines
Limited, in due course, moved to dismiss said complaint on the grounds of prescription under
Article 1146 of the Civil Code where prescription is only four (4) years. On the other hand,
Laureano based his argument on Article 1144 of the Civil Code which provides for a 10-year
prescription.

Issue:
Whether or not the complaint had already prescribed.

Ruling:
Yes. However, neither Article 1144 nor Article 1146 of the Civil Code is here pertinent.
What is applicable is Article 291 of the Labor Code which provides for a 3-year prescriptive period
for money claims arising from employer-employee relationship. What rules on prescription should
apply in cases like this one has long been decided by this Court. In illegal dismissal, it is settled,
that the ten-year prescriptive period fixed in Article 1144 of the Civil Code may not be invoked by
petitioners, for the Civil Code is a law of general application, while the prescriptive period fixed in
Article 291 of the Labor Code is a SPECIAL LAW applicable to claims arising from employee-
employer relations.
Recaña v CA
G.R. No. 123850 January 5, 2001

Doctrine:
Special statute, provided for a particular case or class of cases, is not repealed by a
subsequent statute, general in its terms, provisions and applications, unless the intent to repeal
or alter is manifest, although the terms of the general law are broad enough to include the cases
embraced in the special law.

Facts:
The Land Tenure Administration sold a lot, pursuant to RA 1597, to Macario Arboleda. For
many years, realty taxes on the lot had not been paid both before and after the death of Arboleda.
Thus, on August 26, 1980, the City Treasurer of Manila auctioned the lot for sale due to tax
delinquency, under Presidential Decree No. 464.
Spouses Cirilo and Miguela Montejo purchased the lot at a public auction and were issued
a transfer certificate of title. On April 25, 1984, the Montejos sold the property to Ester Recaña,
heir of Arboleda, who also refunded the amount equivalent to the delinquent taxes paid and other
expenses entailed. Petitioners thus became the owners of the subject lot, evinced by Transfer
Certificate of Title No. 1464015.
The purchase by Ester Recaña and her spouse over the subject lot paved for respondent
Aurora Padpad to file for declaration of co-ownership and partition against petitioners in the
Regional Trial Court of Manila. Padpad contends that they are deemed to have redeemed the
property for all the co-owners, being one of the heir of Arboleda, and further averred that Section
4 of RA 1957 states, among others, that “Every conveyance shall be subject to repurchase by
the original purchaser or his legal heirs within a period of 5 years from the date of conveyance."
Recaña, on the other hand, invoked Section 78 of P.D. No. 464 which provides for a one-
year redemption period for properties foreclosed due to tax delinquency. Thus, according to
petitioners, their repurchase of the property beyond the one-year redemption period under P.D.
No. 464 was outside the ambit of a redemption of foreclosed property, hence, not for the benefit
of all co-owners; Moreover, Recaña maintains that Section 4 of R.A. No. 1597, being inconsistent
with Section 78 of P.D. No. 464, was abrogated and repealed by the latter law, which took effect
later on June 1, 1974.

Issue:
Whether or not Section 78 of PD 464 prevails over Section 4 of R.A. No. 1597.

Ruling:
No. we note that R.A. No. 1597 is a special law enacted specifically to govern all incidents
of the subdivision of the Tondo Foreshore Land. On the other hand, P.D. No. 464 covers all real
property titled to individuals who become delinquents in paying real estate tax. P.D. 464 is a law
of general application. Its provisions have substantially been adopted by the Local Government
Code of 1991, a general statute. Basic in statutory construction is the rule that the enactment of
a later legislation which is a general law cannot be construed to have repealed a special law
unless expressly so stated. Neither can Section 4, R.A. No. 1597 be considered to have been
repealed impliedly. Repeal of laws should be made clear and expressed. Repeals by implication
are not favored as laws are presumed to be passed with deliberation and full knowledge of all
laws existing on the subject. Such repeals are not favored for a law cannot be deemed repealed
unless it is clearly manifest that the legislature so intended it.
Manzano v Valera
G.R. No. 122068 July 8, 1998

Doctrine:
In case of conflict between a general law and a special law, the latter must prevail
regardless of the dates of their enactment.

Facts:
Vilma Bobila filed a complaint for libel against Juanito Manzano in the Municipal Trial Court
(MTC) of Bangued under Judge Redentor Valera. Valera initially recognized that the Regional Trial
Court (RTC) had jurisdiction and forwarded the records to the Office of the Provincial Prosecutor.
However, upon receipt of the records, Prosecutor Flores opined that the MTC should take
cognizance of the case. A month later, Assistant Provincial Prosecutor Ricarte Valera requested
that the records of the case be returned to the MTC. Upon the MTC's acceptance of the case,
petitioner filed a Motion to Dismiss, invoking no jurisdiction over the offense charged. In spite of
this, respondent Judge denied the Motion to Dismiss and thereafter also denied the Motion for
Reconsideration.
In holding that the MTC had jurisdiction, respondent Judge made reference to RA 7691
which according to him, amended Article 360 of the Revised Penal Code. Furthermore, he opined
that although Section 6 RA 7691 does not specifically state what laws fall within the scope of the
amendment, the provision on jurisdiction over libel being inconsistent with the new enactment,
the Code should now be considered amended.

Issue:
Whether or not jurisdiction for libel lies with the MTC.

Ruling:
No. Although RA 7691 was enacted to decongest the clogged dockets of the Regional Trial
Courts by expanding the jurisdiction of first level courts, said law is of a general character. Even
if it is a later enactment, it does not alter the provision of Article 360 of the RPC, a law of a special
nature. "Laws vesting jurisdiction exclusively with a particular court, are special in character, and
should prevail over the Judiciary Act defining the jurisdiction of other courts is a general law." A
later enactment like RA 7691 does not automatically override an existing law, because it is a well-
settled principle of construction that, in case of conflict between a general law and a special law,
the latter must prevail regardless of the dates of their enactment. Jurisdiction conferred by a
special law on the RTC must therefore prevail over that granted by a general law on the MTC.
Heirs of Reyes v Garilao
G.R. No. 136466 November 25, 2009

Doctrine:

Facts:

Issue:

Ruling:
Fort Bonifacio Development Corp. v CIR
G.R. No. 158885 October 2, 2009

Doctrine:

Facts:

Issue:

Ruling:
China Banking Corporation v CA
G.R. No. 121158 December 5, 1996

Doctrine:

Facts:

Issue:

Ruling:
CIR v Bicolandia Drug Corporation
G.R. No. 148083 July 21, 2006

Doctrine:
In cases of conflict between the law and the rules and regulations implementing the law,
the law shall always prevail. Should Revenue Regulations deviate from the law they seek to
implement, they will be struck down.

Facts:
RA 7432 granted tax credit to establishments giving discounts to senior citizens. In its
Implementing Rules and Regulations, IRR No. 2-94 defined tax credit as “the amount representing
the 20% discount granted to a qualified senior citizen by all establishments relative to their
utilization of transportation services, hotels and similar lodging establishments, restaurants, halls,
circuses, carnivals and other similar places of culture, leisure and amusement, which discount
shall be deducted by the said establishments from their gross income for income tax purposes
and from their gross sales for value-added tax or other percentage tax purposes.”
Herein respondent Bicolandia Drug Corporation avidly gave discounts to senior citizens
only to find out that the treatment to its tax liability is that of a tax deduction and not of a tax
credit. Bicolandia thus filed a claim for tax credit and argued that the above IRR is illegal, void
and without effect for being inconsistent with the statute it implements.
Petitioner, however, maintained that Revenue Regulations No. 2-94 is valid since the law
tasked the Department of Finance, among other government offices, with the issuance of the
necessary rules and regulations to carry out the objectives of the law

Issue:
Whether or not IRR No. 2-94 is illegal, void and without effect for being inconsistent with
the statute it implements.

Ruling:
Yes. Revenue Regulations No. 2-94 is still subordinate to R.A. No. 7432, and in cases of
conflict, the implementing rule will not prevail over the law it seeks to implement. While seemingly
conflicting laws must be harmonized as far as practicable, in this particular case, the conflict
cannot be resolved in the manner the petitioner wishes. There is a great divide separating the
idea of "tax credit" and "tax deduction," as seen in the definition in Black's Law Dictionary, which
provides:
An amount subtracted from an individual's or entity's tax liability to arrive at the total tax
liability. A tax credit reduces the taxpayer's liability x x x, compared to a deduction which reduces
taxable income upon which the tax liability is calculated. A credit differs from deduction to the
extent that the former is subtracted from the tax while the latter is subtracted from income before
the tax is computed.

From the above discussion, it must be concluded that Revenue Regulations No. 2-94 is null and
void for failing to conform to the law it sought to implement. In case of discrepancy between the basic law
and a rule or regulation issued to implement said law, the basic law prevails because said rule or regulation
cannot go beyond the terms and provisions of the basic law.
David v COMELEC
G.R. No. 127116 April 8, 1997

Doctrine:

Facts:

Issue:

Ruling: