MODULE 8: INTERPRETATION OF WORDS Corollary principle: where the law does not make any

AND PHRASES exception, courts may not except something therefrom,

unless there a compelling reason to justify it.
I. In General 269
Application: when legislature laid down a rule for one
Generally class, no difference to other class.
A word or phrase used in a statute may have an ordinary,
generic, restricted, technical, legal, commercial or Presumption: that the legislature made no qualification
trading meaning. in the general use of a term.

May be defined in the statute – if this is done, use such CASES:

definition because this is what the legislature intended
1. Republic of the Philippines v. Daisy R. Yahon,
Task: G.R. No. 201043, June 16, 2014 Visayas
-ascertain intent from statute 2. Community Medical Center (VCMC) v. Erma
Yballe, G.R. No. 196156, January 15, 2014
-ascertain intent from extraneous & relevant 3. Republic of the Philippines v. Marelyn Tanedo
circumstance Manalo, G.R. No. 221029, April 24, 2018

-construe word or phrase to effectuate such intent IV. Disjunctive and Conjunctive Words 299
-General rule in interpreting the meaning and scope of a -Word “or” is a disjunctive term signifying
term used in the law: Review of the WHOLE law disassociation and independence of one thing from each
involved as well as the INTENDMENT of law (not of an other.
isolated part or a particular provision alone)
Statute: Sec. 40 of Commonwealth Act 61, punishes
CASES: “any individual who shall bring into or land in the
Philippines or conceals or harbors any alien not duly
1. Joseph Ejercito Estrada v. Sandiganbayan, G.R. No. admitted by any immigration officer...
148560, 19 November 2001
-does not justify giving the word a disjunctive meaning,
2. Jose Jesus M. Disini, jr. v. Secretary of Justice, G.R. since the words “bring into” “land”, “conceals” and
No. 203335, 11 February 2014. “harbors” being four separate acts each possessing its
distinctive, different and disparate meaning.
II. General rules of interpretation
CASES:
1. Atty. Reynante B. Orceo v. COMELEC, G.R.
No. 190779, 26 March 2012 1. Antonio D. Dayao v. COMELEC, G.R. No. 193643,
2. Mustang Lumber, Inc. v. Hon. Court of Appeals, January 29, 2013
G.R. No. 104988, 18 June 1996. 2. People of the Philippines v. Antonio Comadre, G.R.
No. 153559, June 8, 2004 Gonzales
III. Where the law does not distinguish
3. COMELEC, G.R. No. 28196, November 9, 1967
Ubi lex non distinguit, nec nos distinguere debemus -
where the law does not distinguish, courts should not People of the Philippines v. Isidro Flores, G.R. No.
distinguish. 188315, August 25, 2010
Cesar M. Carandang v. Vicente Santiago, G.R. No. L-
Corollary principle: General words or phrases in a 8238, May 25, 1955
statute should ordinarily be accorded their natural and
general significance VI. Ejusdem generis 308

General term or phrase should not be reduced into parts General rule: where a general word or phrase follows
and one part distinguished from the other to justify its an enumeration of particular and specific words of the
exclusion from operation. same class or where the latter follow the former, the
general word or phrase is to be construed to include, or
to be restricted to, persons, things or cases akin to,
resembling, or of the same kind or class as those -where a particular word or phrase is ambiguous in itself
specifically mentioned. or equally susceptible of various meanings, its correct
construction may be made clear and specific by
Purpose: give effect to both particular or general words, considering
by treating the particular words as indicating the class
and the general words as indicating all that is embraced -the company of words in which it is found or with
in said class, although not specifically named by the which it is associated.
particular words.
-to remove doubt refer to the meaning of associated or
Principle: based on proposition that had the legislature companion words
intended the general words to be used in their generic
and unrestricted sense, it would have not enumerated the CASES:
specific words.
1. People of the Philippines v. Isidro Flores, G.R. No.
Presumption: legislators addressed specifically to the 188315, August 25, 2010
particularization 2. Cesar M. Carandang v. Vicente Santiago, G.R. No. L-
8238, May 25, 1955
1. Emeteria Liwag v. Happy Glen Loop
Homeowners’ Association, Inc., G.R. No. VIII. Reddendo singula singulis 339
189755, July 4, 2012
-Variation of the doctrine of last antecedent
2. Commissioner of Customs v. Court of Appeals, -Referring each to each;
G.R. No. 33471, January 31, 1972.
-Referring each phrase or expression to its appropriate
VII. Expressio unius est exclusion alterius and casus object, or let each be put in its proper place, that is, the
omissus 336 word should be taken distributively.

Limitations of the rule CASES:

1. It is not a rule of law, but merely a tool in statutory 1. Ma. Merceditas N. Gutierrez v. The House of
Construction Representatives Committee on Justice, G.R. No.
193459, February 15, 2011
2. Expressio unius est exclusion alterius, no more than
auxiliary rule of interpretation to be ignored where other 2. City of Manila v. Laguio, G.R. No. 118127,
circumstances indicate that the enumeration was not April 12, 2005
intended to be exclusive.
IX. Provisos, Exceptions and Saving Clauses 341
3. Does not apply where enumeration is by way of
example or to remove doubts only.
Provisos Generally.
CASES
-to limit the enacting clause, section, or provision of a
statute.
1. San Pablo Manufacturing Corporation v.
Commissioner of Internal Revenue, G.R. No.
-qualifies or modifies only the phrase immediately
147749, June 22, 2006
preceding
2. Coconut Oil Refiners Assn., Inc. v. Torres, G.R.
Role: restrain or qualify the generality of the enacting
No. 132527, July 29, 2005
clause or section to which it refers
3. The Commission on Audit of the Province of
-To limit or restrict the general language or operation of
Cebu v. Province of Cebu, G.R. No. 141386,
the statute, not to enlarge it
November 29, 2001
-Commonly found at the end of a section or provision of
V. Noscitur a sociis 302
a statute
1. Ricardo Fernandez v. NLRC, G.R. No. 106090,
February 28, 1994

2. Commissioner of Internal Revenue v. Filipinas

Compania De Seguros, G.R. No. L-14880, April
29, 1960

3. Arenas v. City of San Carlos, G.R. No. 34024,

April 5, 1978

4. Chartered Bank of India v. C. A. Imperial, G.R.

No. L-17222, March 15, 1921

5. Roberto S. Benedicto v. Court of Appeals, G.R.

No. 125359, September 4, 2001

6. Balagtas Multi-Purpose Cooperative, Inc. v.

Court of Appeals, G.R. No. 159268, October 27,
2006