Statutory Construction: (Philippines), Inc. vs. Palomar, L-19650, September 29, 1966, 18 SCRA 247)

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STATUTORY CONSTRUCTION lottery, gift enterprise, or scheme for the distribution of

money, or of any real or personal property by lot,


1. Definition of Statutory Construction – chance, or drawing of any kind”.
Statutory construction is the act or process of
discovering and expounding the meaning and Caltex thereupon invoked judicial intervention by filing
intention of the authors of the law with respect a petition for declaratory relief against the Postmaster
to its application at a given case, where that General, praying that judgment be rendered declaring
intention is rendered doubtful, among others, its Caltex Hooded Pump Contest not to be violative of
by reason of the fact that the given case is not the Postal Law and ordering respondent to allow
explicitly provided for in the law. (Caltex petitioner the use of the mail to bring the contest to the
[Philippines], Inc. vs. Palomar, L-19650, attention of the public. The trial court ruled that the
September 29, 1966, 18 SCRA 247) contest does not violate the Postal Code and that the
Postmaster General has no right to bar the public
Construction is drawing of warranted distribution of the contest rules by the mails. The
conclusions beyond direct expression of the Postmaster general appealed to the Supreme Court.
text expressions which are in spirit though not
Issue:
within the text inevitably, there enters into the
construction of statutes the play of JUDICIAL Whether or not the scheme proposed by Caltex
JUDGMENT within the limits of the relevant is within the coverage of the prohibitive provisions of
legislative materials. It involves the EXERCISE the Postal Law inescapably requires an inquiry into the
OF CHOICE BY THE JUDICIARY intended meaning of the words used therein?

Caltex [Philippines], Inc. vs. Palomar, L-19650, Held:


September 29, 1966, 18 SCRA 247
What is prohibited by the Postal Law is Lottery,
Facts: inter alia. Lottery necessarily includes consideration,
prize and chance. Caltex’s contest does include the
In 1960, Caltex Philippines conceived a
elements prize and chance. The Caltex’s contest does
promotional scheme to drum up patronage for its oil
not include consideration as no purchase is required of
products – i.e “Caltex Hooded Pump Contest.” It calls
participant. Is it a gift enterprise? Still no because no
for participants therein to estimate the actual number
purchase. Lottery is prohibited if there is consideration,
of liters a hooded gas pump at each Caltex station will
following noscitur a sociis, the term under construction
dispense during a specified period. Participation is to be
should be accorded no other meaning than that which
open indiscriminately to all “motor vehicle owners
is consistent with the nature of the word associated
and/or licensed drivers”. No fee or consideration is
therewith. But as demonstrated, neither is Caltex’s
required to be paid, no purchase of Caltex products
game a lottery nor a gift enterprise. Hence it should be
required to be made.
allowed to proceed.
Foreseeing the extensive use of the mails for
The SC affirmed the appealed judgment, without costs.
the said contest, Caltex made a letter to the postal
authorities to justify its position that the contest does
not violate the anti-lottery provision of the Postal law. 2. Nature of rules of Statutory Construction –
Unimpressed, the then Acting Postmaster General,
Enrico Palomar, opined that the scheme falls within the Rules of construction, generally
purview of the provisions of the Postal Law – i.e.  Rules of statutory construction are tools used
Chapter 52 od the Revised Administrative Code sections to ascertain legislative intent.
1954(a), 1982 and 1983, which prohibits the non-  NOT rules of law but mere axioms of
mailable matter of any information regarding “any experience
 In enacting a statute, the legislature is  General rule (on mootness) – dismiss
presumed to know the rules of statutory the case
construction, in case of doubt, be construed in o Exception:
accordance with the settled principles of  If capable of
interpretation. repetition, yet evading
 Legislature sometimes adopts rules of review
statutory construction as part of the provisions  Public interest requires
of the statute its resolution
 Legislature also defines to ascertain the  Rendering decision on
meaning of vague, broad words/ terms the merits would be of
practical value
3. Construction and Interpretation
Legislative cannot overrule judicial construction
Construction and interpretation distinguished.  It cannot preclude the courts from giving the
They are so alike in practical results and so are statute different interpretation
used interchangeably synonymous;  Legislative – enact laws
 Executive- to execute laws
Construction - process of drawing warranted
 Judicial- interpretation and application
conclusions not always included in direct
 If the legislature may declare what a law means
expressions, or determining the application of
– it will cause confusion…it will be violative of
words to facts in litigation
the fundamental principles of the constitution
of separation powers.
Interpretation - art of finding the true meaning
 Legislative construction is called resolution or
and sense of any form of words
declaratory act

4. Power to construe and its limitations Endencia v David

POWER TO CONSTRUE  Explains why legislative cannot overrule


Construction is a judicial function Supreme Court’s decision
 It is the court that has the final word as
Perfecto v. Meer
to what the law means.
 It construes laws as it decide cases  Art. 8 Sec. 9 1935 Constitution – SC’s
based on fact and the law involved interpretation: “shall receive such
 Laws are interpreted in the context of compensation as may be fixed by law, which
a peculiar factual situation of each case shall not be diminished during their
 Circumstances of time, place, event, continuance in office” – exempt from income
person and particularly attendant tax
circumstances and actions before,  Legislative passed RA 590 Sec. 13 – “no salary
during and after the operative fact whenever received by any public officer of the
have taken their totality so that justice Republic shall be considered exempt from the
can be rationally and fairly dispensed. income tax, payment of which is hereby
 Moot and academic – declared not to be a diminution of his
o Purpose has become stale compensation fixed by the Constitution or by
o No practical relief can be law”
granted  Source of confusion
o Relief has no practical effect  Violative of principle on separation of powers
 RA 590 Sec 13 – unconstitutional Court may not construe where statute is clear
 Art 8 Sec. 9 1935 – repealed by Art. 15 Sec. 6
 A statute that is clear and unambiguous is not
1973 Constitution – “no salary or any form of
susceptible of interpretations.
emolument of any public officer or employee,
 First and fundamental duty of court – to apply
including constitutional officers, shall be
the law
exempt from payment of income tax”
 Construction – very last function which the
 Thus, judiciary is not exempt from payment of
court should exercise
tax anymore
 Law is clear – no room for interpretation, only
When judicial interpretation may be set aside room for application
 Courts cannot enlarge or limit the law if it is
 “Interpretations may be set aside.” The
clear and free from ambiguity (even if law is
interpretation of a statute or a
harsh or onerous
constitutional provision by the courts is
 A meaning that does not appear nor is intended
not so sacrosanct as to be beyond
or reflected in the very language of the statute
modification or nullification.
cannot be placed therein by construction.
 The Supreme Court itself may, in an
appropriate case change or overrule its Rulings of Supreme Court part of legal system
previous construction.
 The rule that the Supreme Court has  Art. 8 CC – “Judicial decisions applying or
the final word in the interpretation or interpreting the laws or the Constitution shall
construction of a stature merely means form part of the legal system of the
that the legislature cannot, by law or Philippines”
resolution, modify or annul the judicial  Legis interpretato legis vim obtinet –
construction without modifying or authoritative interpretation of the SC of a
repealing the very statute which has statute acquires the force of law by becoming a
been the subject of construction. It can, part thereof as of the date of its enactment ,
and it has done so, by amending or since the court’s interpretation merely
repealing the statute, the consequence establishes the contemporaneous legislative
of which is that the previous judicial intent that the statute thus construed intends
construction of the statute is modified to effectuate
or set aside accordingly.  Stare decisis et non quieta novere – when the
SC has once laid down a principle of law as
When court may construe statute applicable to a certain state of facts, it will
adhere to that principle and apply it to all
 “The court may construe or interpret a statute
future cases where the facts are substantially
under the condition that THERE IS DOUBT OR
the same o For stability and certainty
AMBIGUITY”
 Supreme Court becomes, to the extent
 Ambiguity – a condition of admitting 2 or more
applicable, the criteria that must control the
meanings. Susceptible of more than one
actuations not only of those called upon to
interpretation.
abide thereby but also of those duty-bound to
 Only when the law is ambiguous or doubtful of
enforce obedience thereto.
meaning may the court interpret or construe its
 SC rulings are binding on inferior courts
intent.
Judicial rulings have no retroactive effect Strict or Liberal Construction

 Lex prospicit not respicit - the law looks IN GENERAL


forward, not backward
Generally
 Rationale: Retroactive applications of a law
usually divest rights that have already become  Whether a statute is to be given a strict or
vested or impairs he obligations of contract and liberal construction will depend upon the
hence is unconstitutional. following:
o The nature of the statute
LIMITATIONS ON POWER TO CONSTRUE
o The purpose to be sub served
Courts may not enlarge nor restrict statutes o The mischief to be remedied
 Purpose: to give the statute the interpretation
 Courts are not authorized to insert into the law
that will best accomplish the end desired and
what they think should be in it or to supply
effectuate legislative intent
what they the legislature would have supplied
if its intention had been called to the omission. Strict construction, generally
 They should not by construction, revise even
the most arbitrary or unfair action of the  Construction according to the letter of the
legislature, nor rewrite the law to conform to statute, which recognizes nothing that is not
what they think should be the law. expressed, takes the language used in its exact
 Neither should the courts construe statutes meaning, and admits no equitable
which are perfectly vague for it violates due consideration
process  Not to mean that statutes are construed in its
o Failure to accord persons fair notice of narrowest meaning
the conduct to avoid  It simply means that the scope of the statute
o Leave law enforcers unbridled shall not be extended or enlarged by
discretion in carrying out its provisions implication, intendment, or equitable
 2 leading stars on judicial construction consideration beyond the literal meaning of its
o Good faith terms
o Commonsense  It is a close and conservative adherence to the
literal or textual interpretation
 an utterly vague act on its face cannot be
 The antithesis of liberal construction
clarified by either a saving clause or by
construction Liberal construction, defined
Courts not to be influenced by questions of wisdom  Equitable construction as will enlarge the letter
of a statute to accomplish its intended purpose,
 Courts do not sit to resolve the merit of
carry out its intent, or promote justice
conflicting theories
 Not to mean enlargement of a provision which
 Courts do not pass upon question of wisdom,
is clear, unambiguous and free from doubt
justice or expediency of legislation, for it’s not
 It simply means that the words should receive a
within their province to supervise legislation
fair and reasonable interpretation, so as to
and keep it within the bounds of common
attain the intent, spirit and purpose of the law
sense.
 The court merely interpret regardless of Liberal construction applied, generally
whether or not they wise or salutary.
 Where a statute is ambiguous, the literal
meaning of the words used may be rejected if
the result of adopting said meaning would be to Construction taking into consideration general welfare
defeat the purpose of the law or growth civilization

 Ut res magis valeat quam pereat – that  Construe to attain the general welfare
construction is to be sought which gives effect  Salus populi est suprema lex – the voice of the
to the whole of the statute – its every word people is the supreme law
 Statuta pro publico commodo late
interpretantur – statutes enacted for the public
good are to be construed liberally
 Liberal Construction - Equitable
 The reason of the law is the life of the law; the
construction as will enlarge the
reason lies in the soil of the common welfare
letter of a statute to accomplish
 The judge must go out in the open spaces of
its intended purpose, carry out
actuality and dig down deep into his common
its intent, or promote justice.
soil, if not, he becomes subservient to
Legitimate exercise of judicial
formalism
power
 Construe in the light of the growth of civilization
 Judicial Interpretation - Act of
and varying conditions o The interpretation that
the court in engrafting upon a
“if the man is too long for the bed, his head
law something which it believes
should be chopped off rather than enlarge the
ought to have been embraced
old bed or purchase a new one” should NOT be
therein.
given to statutes
Forbidden by the tripartite
division of powers among the 3 STATUTES STRICTLY CONSTRUED
departments of government.
Penal statutes, generally
 A statute may not be liberally construed to
 Penal statutes are those that define crimes,
read into it something which its clear and plain
treat of their nature and provide for their
language rejects
punishment o Acts of legislature which prohibit
Construction to promote social justice certain acts and establish penalties for their
violation
 Social justice must be taken into account in the  Those which impose punishment for an offense
interpretation and application of laws committed against the state, and which the
 Social justice mandate is addressed or meant chief executive has the power to pardon
for the three departments: the legislative,  A statute which decrees the forfeiture in favor
executive, and the judicial of the state of unexplained wealth acquired by
 Social justice (included in the Constitution) was a public official while in office is criminal in
meant to be a vital, articulate, compelling nature
principle of public policy
 It should be observed in the interpretation not Penal statutes, strictly construed
only of future legislations, but also of laws
 Penal statutes are strictly construed against the
already existing on November 15, 1935.
State and liberally construed in favor of the
 It was intended to change the spirit of our laws,
accused
present and future.
o Penal statutes cannot be enlarged or
extended by intendment, implication,
or any equitable consideration
o No person should be brought within its  Rights are not absolute, and the state, in the
terms if he is not clearly made so by exercise of police power, may enact legislations
the statute curtailing or restricting their enjoyment
o No act should be pronounces criminal  As these statutes are in derogation of common
which is not clearly made so or general rights, they are generally strictly
construed and rigidly confined to cases clearly
Reason why penal statutes are strictly construed within their scope and purpose
 The law is tender in favor of the rights of the  Examples:
individual; o Statutes authorizing the expropriation
 The object is to establish a certain rule by of private land or property
conformity to which mankind would be safe, o Allowing the taking of deposition o
and the discretion of the court limited o Fixing the ceiling of the price of
 Purpose of strict construction is NOT to enable commodities
a guilty person to escape punishment through o Limiting the exercise of proprietary
technicality but to provide a precise definition rights by individual citizens
of forbidden acts o Suspending the period of prescription
of actions
Acts mala in se and mala prohibita  When 2 reasonably possible constructions, one
which would diminish or restrict fundamental
 General rule: to constitute a crime, evil intent
right of the people and the other if which would
must combine with an act
not do so, the latter construction must be
 Actus non facit reum nisi mens sit rea – the act
adopted so as to allow full enjoyment of such
itself does not make a man guilty unless his
fundamental right
intention were so
 Actus me invite factus non est meus actus – an Statutes authorizing expropriations
act done by me against my will is not my act
 Power of eminent domain is essentially
Mala in se - Criminal intent, apart from the act itself is legislative in nature
required, RPC  May be delegated to the President, LGUs, or
public utility company
Mala prohibita - The only inquiry is, has the law been
 Expropriation plus just compensation
violated RPC Special penal laws, Special penal laws
 A derogation of private rights, thus strict
 However, if special penal laws use such words construction is applied
as “willfully, voluntarily, and knowingly” intent  Statutes expropriating or authorizing the
must be proved; thus good faith or bad faith is expropriation of property are strictly construed
essential before conviction against the expropriating authority and liberally
in favor of property owners
Limitation of rule
Statutes granting privileges
 Limitation #1 – Where a penal statute is capable
of 2 interpretations, one which will operate to  Statutes granting advantages to private persons
exempt an accused from liability for violation or entities have in many instances created
thereof and another which will give effect to special privileges or monopolies for the
the manifest intent of the statute and promote grantees and have thus been viewed with
its object, the latter interpretation should be suspicion and strictly construed
adopted  Privilegia recipient largam interpretationem
voluntati consonam concedentis – privileges are
Statutes in derogation of rights
to be interpreted in accordance with the will of takes from them a portion of their property for
him who grants them the support of the government
 And he who fails to strictly comply with the will
Statutes granting tax exemptions
of the grantor loses such privileges
 Law frowns against exemption from taxation
Legislative grants to local government units
because taxes are the lifeblood of the nation
 Grants of power to local government are to be  Laws granting tax exemptions are thus
construed strictly, and doubts in the construed strictissimi juris against the taxpayer
interpretation should be resolved in favor of and liberally in favor of the taxing authority
the national government and against the  Burden of proof – on the taxpayer claiming to
political subdivisions concerned be exempted
 Reason: there is in such a grant a gratuitous  Basis for strict construction – to minimize the
donation of public money or property which different treatment and foster impartiality,
results in an unfair advantage to the grantee fairness, and equality of treatment among
and for that reason, the grant should be taxpayers
narrowly restricted in favor of the public  Tax exemptions are not favored in law, nor are
they presumed.
Statutory grounds for removal of officials
Qualification of rule
 Statutes relating to suspension or removal of
public officials are strictly construed  Strict construction does not apply in the case of
 Reason: the remedy of removal is a drastic one tax exemptions in favor of the government itself
and penal in nature. Injustice and harm to the or its agencies
public interest would likely emerge should such  Provisions granting exemptions to government
laws be not strictly interpreted against the agencies may be construed liberally in favor of
power of suspension or removal non-tax liability of such agencies
 The express exemption should not be construed
with the same degree of strictness that applies
Naturalization laws to exemptions contrary to policy of the state,
since as to such property exemption is the rule
 Naturalization laws are strictly construed and the taxation is the exemption
against the applicant and rigidly followed and  E.g. tax exemption in favor of NAPOCOR –
enforced whether direct or indirect taxes, exempted
 Naturalization is statutory than a natural right
Statutes imposing taxes and customs duties Statutes concerning the sovereign
 Tax statutes must be construed strictly against
 Restrictive statutes which impose burdens on
the government and liberally in favor of the
the public treasury or which diminish rights and
taxpayer
interests are strictly construed.
 Power to tax involves power to destroy
 Unless so specified, the government does not
 Taxing act are not to be extended by
fall within the terms of any legislation
implication
 Tax statutes should be clearly, expressly, and
unambiguously imposed
 Reason for strict construction: taxation is a
destructive power which interferes with the Statutes authorizing suits against the government
personal property rights of the people and
 Art. XVI, Sec. 3, 1987 Constitution – “The State  A proviso should be interpreted strictly with
may not be sued without its consent” the legislative intent
o General rule: sovereign is exempt from o Should be strictly construed
suit o Only those expressly exempted by the
o Exception: in the form of statute, state proviso should be freed from the
may give its consent to be sued operation of the statute
 Statute is to be strictly
construed and waiver from STATUTES LIBERALLY CONSTRUED
immunity from suit will not be General social legislation
lightly inferred
 Nullum tempus occurrit regi – there can be no  General welfare legislations
legal right as against the authority that makes o To implement the social justice and
the law on which the right depends protection-tolabor provisions of the
 Reason for non-suability – not to subject the Constitution
state to inconvenience and loss of o Construed liberally
governmental efficiency. o Resolve any doubt in favor of the
persons whom the law intended to
Statutes prescribing formalities of the will
benefit
 Strictly construed, which means, wills must be o Includes the following – labor laws,
executed in accordance with the statutory tenancy laws, land reform laws, and
requirements, otherwise, it is entirely void social security laws
 The court is seeking to ascertain and apply the  Liberal construction applies only if statute is
intent of the legislators and not that of the vague, otherwise, apply the law as it is stated
testator, and the latter’s intention is frequently
General welfare clause
defeated by the non-observance of what the
statute requires  2 branches
o One branch attaches to the main trunk
Exceptions and provisos
of municipal authority – relates to such
 Should be strictly but reasonably construed ordinances and regulations as may be
 All doubts should be resolved in favor of the necessary to carry into effect and
general provision rather than the exceptions discharge the powers and duties
o However, always look at the intent of conferred upon local legislative bodies
legislators if it will accord reason and by law
justice not to apply the rule that “an o Other branch is much more
express exception excludes all others” independent of the specific functions
 The rule on execution pending appeal must be enumerated by law – authorizes such
strictly construed being an exception to the ordinances as shall seem necessary and
general rule proper to provide for the health and
 Situations which allows exceptions to the safety, promote the prosperity, improve
requirement of warrant of arrest or search the morals, peace, good order xxx of
warrant must be strictly construed; to do so the LGU and the inhabitants thereof,
would infringe upon personal liberty and set and for the protection of the property
back a basic right therein
 A preference is an exception to the general rule  Construed in favor of the LGUs
 To give more powers to local governments in
promoting the economic condition, social
welfare, and material progress of the people in  Beneficial for both government and taxpayer
the community o To the government – tax officers are
 Construed with proprietary aspects, otherwise obliged to act promptly in the making
would cripple LGUs of the assessments
 Must be elastic and responsive to various social o To the taxpayer – would have a feeling
conditions of security against unscrupulous tax
 Must follow legal progress of a democratic way agents who will always find an excuse
of life to inspect the books of taxpayers
 Laws on prescription – remedial measure –
Grant of power to local governments
interpreted liberally affording protection to the
 Old rule: municipal corporations, being mere taxpayers
creatures of law, have only such powers as are
Statutes imposing penalties for nonpayment of tax
expressly granted to them and those which are
necessarily implied or incidental to the exercise  liberally construed in favor of government and
thereof strictly construed against the taxpayer
 New rule: RA 2264 “Local Autonomy Act”  intention to hasten tax payments or to punish
o Sec 12 – “implied power of a province, a evasions or neglect of duty in respect thereto
city, or a municipality shall be liberally  liberal construction would render penalties for
construed in its favor. Any fair and delinquents nugatory
reasonable doubt as to the existence of
the power should be interpreted in Election laws
favor of the local government and it  Election laws should be reasonably and liberally
shall be presumed to exist” construed to achieve their purpose
Statutes granting taxing power (on municipal  Purpose – to effectuate and safeguard the will
corporations) of the electorate in the choice of their
representatives
 Before 1973 Constitution – inferences,  3 parts
implications, and deductions have no place in o Provisions for the conduct of elections
the interpretation of the taxing power of a which election officials are required to
municipal corporation follow
 New Constitution – Art. X, Sec 5 1987 o Provisions which candidates for office
Constitution – “each local government unit shall are required to perform
have the power to create its own sources of o Procedural rules which are designed to
revenue and to levy taxes, fees, and charges ascertain, in case of dispute, the actual
subject to such guidelines and limitations as the winner in the elections
Congress may provide, consistent with the basic
policy of local autonomy” Different rules and canons or statutory
o Statutes prescribing limitations on the construction govern such provisions of the
taxing power of LGUs must be strictly election law
construed against the national  Part 1:
government and liberally in favor of the o Rules and regulations for the
LGUs, and any doubt as to the existence conduct of elections
of the taxing power will be resolved in  Before election –
favor of the local government mandatory (part 1)

Statutes prescribing prescriptive period to collect taxes


 After election – Amnesty proclamations
directory (part 3)
 Amnesty proclamations should be
o Generally – the provisions of a liberally construed as to carry out their
purpose
statute as to the manner of
conducting the details of an  Purpose – to encourage to return to the
election are NOT mandatory; and fold of the law of those who have
irregularities in conducting an veered from the law
election and counting the votes, not  E.g. in case of doubt as to whether
preceding from any wrongful intent certain persons come within the
and which deprives no legal voter of amnesty proclamation, the doubt
his votes, will not vitiate an election should be resolved in their favor and
or justify the rejection of the entire against the state
votes of a precinct  Same rule applies to pardon since
 Against pardon and amnesty is synonymous
disenfranchisement Statutes prescribing prescriptions of crimes
 Remedy against
election official who  Liberally construed in favor of the accused
did not do his duty  Reason – time wears off proof and innocence
– criminal action  Same as amnesty and pardon
against them
 Part 2: Adoption statutes
o Provisions which candidates
 Adoption statutes are liberally construed in
for office are required to favor of the child to be adopted
perform are mandatory o  Paramount consideration – child and not the
Non-compliance is fatal adopters
 Part 3:
o Procedural rules which are Veteran and pension laws
designed to ascertain, in
 Veteran and pension laws are enacted to
case of dispute, the actual
compensate a class of men who suffered in the
winner in the elections are
service for the hardships they endured and the
liberally construed
dangers they encountered in line of duty
o Technical and procedural
o Expression of gratitude to and
barriers should not be
recognition of those who rendered
allowed to stand if they
service to the country by extending to
constitute an obstacle in
them regular monetary benefit
the choice of their elective
 Veteran and pension laws are liberally
officials
construed in favor of grantee
 For where a candidate has received
popular mandate, overwhelmingly and Rules of Court
clearly expressed, all possible doubts
should be resolved in favor of the  RC are procedural – to be construed liberally
candidates eligibility, for to rule  Purpose of RC – the proper and just
otherwise is to defeat the will of the determination of a litigation
electorate.  Procedural laws are no other than
technicalities, they are adopted not as ends in
themselves but as means conducive to the
realization of the administration of law and
justice.
 RC should not be interpreted to sacrifice
substantial rights at the expense of
technicalities.
 Liberal construction of RC does not mean they
may be ignored; they are required to be
followed except only for the most persuasive
reasons.

Other statutes

 Curative statutes – to cure defects in prior law


or to validate legal proceedings which would
otherwise be void for want of conformity with
certain legal requirements; retroactive
 Redemption laws – remedial in nature –
construed liberally to carry out purpose, which
is to enable the debtor to have his property
applied to pay as many debtor’s liability as
possible
 Statutes providing exemptions from execution
are interpreted liberally in order to give effect
to their beneficial and humane purpose
 Laws on attachment – liberally construed to
promote their objects and assist the parties
obtaining speedy justice
 Warehouse receipts – instrument of credit –
liberally construed in favor of a bona fide
holders of such receipts
 Probation laws – liberally construed
o Purpose: to give first-hand offenders a
second chance to maintain his place in
society through the process of
reformation
 Statute granting powers to an agency created
by the Constitution should be liberally
construed for the advancement of the
purposes and objectives for which it was
created

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