Case Digest (G.R. No. 42935)
Facts:
Petitioner Felipe Regalado qualified as justice of the peace of Malinao, Albay on April 12, 1906. Act No. 3899 amending Section 203 of the Administrative Code took effect November 16, 1931; Regalado turned 65 on September 13, 1934, after which the judge of first instance, pursuant to instructions from the Secretary of Justice, designated Esteban T. Villar to act as justice of the peace; Villar qualified December 17, 1934, and Regalado filed quo warranto.
Issues:
- Whether under Section 203, as amended by Act No. 3899, a justice of the peace appointed prior to the Act who reached 65 after the Act took effect ceases to hold office upon attaining that age?
Ruling:
The Court granted the writ of quo warranto, ousted Esteban T. Villar, and ordered Felipe Regalado restored to possession of the office; no special pronouncement as to costs.
Ratio:
The Court held that the Spanish text of Act No. 3899 controlled and that the phrase al tiempo de la vigencia de esta ley means "at the time this Act takes effect" (November 16, 1931), so the proviso in the past tense referred only to those who had completed 65 by that date. The Court declined to rewrite the statute or insert words to effect a retroactive operation despite legislative history and the Secretary's construction, and it noted that administrative construction is persuasive but not binding where the statutory language is plain (citing Chanco v. Imperial and Segovia v. Noel).
Doctrine:
- The Spanish text governs the interpretation of a statute enacted in Spanish.
- (Get Pro to unlock 2 more doctrines)