Submitted by: Pat P.

Monte

Caltex vs. Palomar, G.R. No. L-19650, 29 September 1966

Facts:

1. In the 1960, Caltex conceived a promotional scheme to help increase its

patronage and boost their sales for oil products, which they called “Caltex
Hooded Pump Contest.”
2. The contest calls for participants to estimate the number of liters a hooded
gas pump at each Caltex station will dispense during a specified period.
3. To participate, entry forms are only needed which can be made available
upon request at each Caltex station. No fee is required to be paid nor
purchase has to be made prior to participating.
4. Expecting the extensive use of mails to publicize the promotional scheme,
Caltex made representations with the postal authorities to secure
advanced clearance for mailing. Caltex, through its counsel, posited
that the contest does not violate anti-lottery provisions of the Postal Law.
5. The Postmaster General Palomar declined the grant of the requested
clearance. Caltex sought a reconsideration. Palomar maintained that if the
contest was pursued, a fraud order will be issued against Caltex. Thus,
this case at bar.

Issue:

Whether or not the proposed contest violates the Postal Law for being similar
to a Lottery.

Ruling: No.

The Court held that the petition states a sufficient cause of action for declaratory
relief since it qualifies for the 4 requisites on invoking declaratory relief available
to any person whose rights are affected by a statute to determine any question
of construction or validity. To the petitioner, the construction hampers or
disturbs its freedom to enhance its business while to the respondent,
suppression of the petitioner’s proposed contest believed to transgress the law
he has sworn to uphold and enforce is an unavoidable duty.

Likewise, using the rules of Statutory Construction in discovering the meaning

and intention of the authors in a case clouded with doubt as to its application,
it was held that the promotional scheme does not violate the Postal Law in that
it does not entail lottery or gift enterprise. Using the principle “noscitur a sociis’,
the term under construction shall be understood by the words preceding and
following it. Thus, using the definitions of lottery and gift enterprise which both
has the requisites of prize, chance and consideration, the promo contest does
not clearly violate the Postal Law because of lack of consideration.

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1. Roberts vs. Portland Water District, 126 A 112

Facts:

1. Portland Water District Initiated a condemnation proceedings, by right of

eminent domain under authority of a Private or Special Act.
2. The owner of the property so taken may have the question of the necessity
of the appropriation for public use judicially determined, and such part of
the land so taken as the court shall determine as being necessary, or the
whole of the land so taken if found to be necessary, shall be appropriated,
and damages awarded accordingly.
3. If any of the land is judicially determined as necessary, the moving party
in the condemnation proceedings is considered as prevailing and entitled
to costs.
4. If any part of the land taken is necessary for public uses such part may be
appropriated upon payment of damages, the costs being taxable against
the petitioner, the other party being the prevailing party.

Issue:
Whether the land taken is necessary for public uses such party may be
appropriated upon payment of damages.

Ruling:

The Portland Water District under authority of Chapter 433 of the Private
and Special Laws of 1907, under condemnation proceedings, took certain land
owned by the plaintiffs for the purpose of constructing a new conduit and for
other water-works improvements. Commissioners were appointed to determine
the question of necessity under Secs. 23 to 26 of Chap. 61, R. S., the owners of
the land claiming that the taking was not necessary. After a hearing the
commissioners found that it was necessary to take a part of the land but not the
whole of it, and the plaintiffs contended that the commissioners could not make
such a finding of fact, but must find that the whole or none of the land was
necessary, but the presiding Justice ruled against the plaintiffs who entered
exceptions, and the presiding Justice also ruled that the respondent was the
prevailing party and entitled to costs under R. S., Chap. 61, Sec. 25, and
plaintiffs excepted. Exceptions overruled.

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City of Baguio vs. Marcos, G.R. No. L-26100, 28 February 1969

Facts:

1. In April 12, 1912, the director of lands in the CFI of Baguio Filed for the
reopening of cadastral proceedings. In November 13, 1922, a decision was
rendered.
2. The land involved was the Baguio Townsite which was declared public
land.
3. In July 25, 1961, Belong Lutes petitioned to reopen the civil case on the
following grounds: 1) he and his predecessors have been in continuous
possession and cultivation of the land since Spanish times; 2) his
predecessors were illiterate Igorots, thus, were not able to file their claim.
4. F. Joaquin Sr., F. Joaquin Jr., and Teresita Buchholz opposed Lutes’
reopening on the following grounds: 1) the reopening was filed outside the
40-year period provided in RA 931; 2) the petition to reopen the case was
not published; and 3) as lessees of the land, they have standing on the
issue.

Issue: Whether or not the reopening of the petition was filed outside the 40-
year period provided in RA 931, which was ENACTED on June 20, 1953

Ruling:

The title of RA 931 was “An Act to Authorize the Filing in Proper Court
under Certain Conditions, of Certain Claims of Title to Parcels of Land that
have been Declared Public Land, by Virtue of Judicial Decisions RENDERED
within the 40 Years Next Preceding the Approval of this Act.” Section 1 of the
Act reads as “..in case such parcels of land, on account of their failure to file
such claims, have been, or about to be declared land of the public domain by
virtue of judicial proceedings INSTITUTED within the 40 years next preceding
the approval of this act.” If the title is to be followed, November 13, 1922 is
the date which should be followed, hence, would allow the reopening of the
case. If Section 1 is to be followed, the date of the institution of reopening of
the case which was April 12, 1912, the petition would be invalid.

The title is an indispensable part of a statute, and what may inadequately

be omitted in the text may be supplied or remedied by its title.

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National Federation of Labor (NFL) v. Eisma GR L-61236, 31 January 1984
(127 SCRA 419)

Facts:

1. On 5 March 1982, the National Federation of Labor filed with the Ministry
of Labor and Employment (Labor Relations Division, Zamboanga City), a
petition for direct certification as the sole exclusive collective bargaining
representative of the monthly paid employees at the Lumbayao
manufacturing plant of the Zamboanga Wood Products, Inc.
(Zambowood).

2. On 17 April 1982, such employees charged the firm before the same office
for underpayment of monthly living allowances.

3. On 3 May 1982, the union issued a notice of strike against the firm,
alleging illegal termination of Dionisio Estioca, president of the said local
union; unfair labor practice; nonpayment of living allowances; and
“employment of oppressive alien management personnel without proper
permit. The strike began on 23 May 1982.

4. On 9 July 1982, Zambowood filed a complaint with the trial court against
the officers and members of the union, for “damages for obstruction of
private property with prayer for preliminary injunction and/or restraining
order.” The union filed a motion for the dismissal and for the dissolution
of the restraining order, and opposition to the issuance of the writ of
preliminary injunction, contending that the incidents of picketing are
within the exclusive jurisdiction of the Labor Arbiter pursuant to Batas
Pambansa 227 (Labor Code, Article 217) and not to the Court of First
Instance.

5. The motion was denied. Hence, the petition for certiorari.

Issue:
Whether construction of the law is required to determine jurisdiction.

Ruling:

The first and fundamental duty of courts is to apply the law. Construction
and interpretation come only after it has been demonstrated that application
is impossible or inadequate without them.

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 Jurisdiction over the subject matter in a judicial proceeding is conferred
by the sovereign authority which organizes the court; and it is given only by
law. Jurisdiction is never presumed; it must be conferred by law in words
that do not admit of doubt. Since the jurisdiction of courts and judicial
tribunals is derived exclusively from the statutes of the forum, the issue
should be resolved on the basis of the law or statute in force. Therefore, since
(1) the original wording of Article 217 vested the labor arbiters with
jurisdiction; since (2) Presidential Decree 1691 reverted the jurisdiction with
respect to money claims of workers or claims for damages arising from
employer-employee relations to the labor arbiters after Presidential Decree
1367 transferred such jurisdiction to the ordinary courts, and since (3) Batas
Pambansa 130 made no change with respect to the original and exclusive
jurisdiction of Labor Arbiters with respect to money claims of workers or
claims for damages arising from employer-employee relations; Article 217 is
to be applied the way it is worded. The exclusive original jurisdiction of a
labor arbiter is therein provided for explicitly. It means, it can only mean,
that a court of first instance judge then, a regional trial court judge now,
certainly acts beyond the scope of the authority conferred on him by law
when he entertained the suit for damages, arising from picketing that
accompanied a strike.

The Supreme Court, thus, granted the writ of certiorari, and nullified and
set aside the 20 July 1982 order issued by the court a quo. It granted the
writ of prohibition, and enjoined the Judge of said court, or whoever acts in
his behalf in the RTC to which this case is assigned, from taking any further
action on the civil case (Civil Case 716 [2751]), except for the purpose of
dismissing it. It also made permanent the restraining order issued on 5
August 1982.

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LEONARDO A. PAAT (OIC-DENR), JOVITO LAYUGAN, JR. (CENRO-DENR) vs.
COURT OF APPEALS, HON. RICARDO A. BACULI, SPOUSES BIENVENIDO
AND VICTORIA DE GUZMAN G.R. No. 111107, JANUARY 10, 1997

Facts:

1. On May 19, 1989, the truck of Victoria de Guzman was seized by the
DENR personnel in Aritao, Nueva Ecija when it was on its way to Bulacan
because the driver was not able to produce the required forest documents
for the forest products found concealed in the truck.

2. The CENRO of Aritao issued on May 23, 1989 an order of confiscation and
gave the owners 15 days to submit an explanation. However, the owners
failed to submit the required explanation.

3. The DENR Regional Director Baggayan sustained the confiscation and

order of forfeiture. The private respondents filed a case of replevin to the
Regional Trial Court Branch 2 of Cagayan. They contended that the DENR
has no authority to confiscate and forfeit conveyances used in
transporting illegal forest products in favor of the government but rather
the court, based on the second paragraph of Section 68 of PD 705, as
amended by EO 277.

4. In addition, they argued that since there is no crime punishable is the

same Section other than qualified theft, and the petitioners admitted that
they could not be charged with such offense, hence, their truck should
not be confiscated.

5. The RTC decided in favour of the respondents. The petitioners filed a

petition for certiorari to the Supreme Court.

Issue:
Whether or not the petitioners violated Section 68 of PD 705, as amended by EO
277, which shall, therefore, be a ground for confiscation of their truck?

Ruling:

When the statute is clear and explicit, there is hardly room for any
extended court ratiocination or rationalization. It is clear in the introduction of
EO 277 amending Sec. 68 of PD 705 that to ―cut, gather, collect, remove or
possess any timber or other forest products without the legal documents as

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require by the existing forest laws and regulations, shall be punished with the
penalties imposed under Art. 309 and 310 of the RPC‖. Then it is obvious that
petitioners have the violated EO 277 when its truck which contains forest
products was not able to present legal documents. The truck should, Therefore,
be subject for confiscation.

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