Statutory Construction- People vs. Yu Hai alias “HAYA”

Statutory Construction

- Headnotes and Epigraphs
- Construction to avoid Absurdity


Case of People of the Philippines vs. Yu Hai alias “HAYA”
GR Nos. L- 9598, 38216 15August1956

FACTS OF THE CASE:
On October 22, 1954, the accused was charged in the Justice of the Peace Court of Caloocan of a violation of Article 195, sub-paragraph 2 of the Revised Penal Code, for having allegedly permitted the game of panchong or paikiu, a game of hazard, and having acted as maintainer thereof. The accused moved to quash the information on the ground that it charged more than one offense and that the criminal action or liability therefore had already been extinguished; and the Justice of the Peace of Court, in its order of December 24, 1954, sustained the motion to quash on the theory that the offense charged was a light offense which, under Article 90 of the Revised Penal Code, prescribed in two months.

ISSUES OF THE CASE:

Did the court err in considering the offense committed as a light felony?

No, since the light offenses as defined in art 9 of the R.P.C states that “an offense which penalty arresto menor or a fine not exceeding 200 pesos." The argument of the SolGen on the matter is erroneous since the basis for his argument of classifying the offense committed as a correctional penalty, is Art 26 of the RPC which classifies fines not offenses.

Also, if the SolGen’s interpretation of the law is accepted then it will lead to and absurd situation wherein a light felony as defined by Art 9 will have 2 prescriptive periods, and 1 peso will mean the difference of 9 years and 10 months, and there is no reason for a law-maker to raise the prescriptive period for certain light offenses over other light offenses

Therefore it is more sensible and to apply Art 9 over Art 26 since we are discussing the prescription of a crime not the penalty. An as this construction is more favorable to the accused, it should be the one to be adopted.

HELD:

THE DECISION IS AFFIRMED WITH COSTS DE OFICIO.

STATUTORY CONSTRUCTION LESSON:

Headnotes or epigraphs- When a statute is divided into several subjects or articles, having respective appropriate headings, it must be presumed that the provisions of each article are controlling upon the subject thereof and operate as a general rule for settling such questions therein.

Construction to avoid absurdity- If the words of the statute are susceptible of more than one meaning, the absurdity of the result of one construction is a strong argument against its adoption, and in favor of such sensible interpretation as will avoid such result.

I hope this helps.

Jeff David