Many senators and readers often ponder about the proper way to read and interpret newly enacted laws like the Maharlika Investment Fund (MIF) law. Should they be interpreted based on the language used or the intentions of the lawmakers? While this question may seem straightforward, the answer is far from simple.
Fortunately, a young and accomplished professor named Ricardo M. Pilares III, who was the Ateneo law valedictorian and ranked second in the 2006 bar exams, has recently released an updated edition of his book titled “Statutory Construction: Concept and Cases.” Although the book is primarily aimed at lawyers and law students, it is written in a language that is easily understandable to the average person (excluding direct quotes from Supreme Court decisions).
According to Pilares, and I fully concur, the fundamental principle in statutory construction is to determine the original intent of the lawmakers and apply it to a given set of circumstances using either verba legis (the plain meaning rule) or ratio legis (the reason of the law).
Verba legis dictates that if a statute is clear, unambiguous, and devoid of any confusion or uncertainty, its literal meaning must be followed without resorting to other rules of interpretation. The Supreme Court has stated that lawmakers are presumed to have a thorough understanding of the words they use and have deliberately chosen them to express their intent. Therefore, the intent of the lawmakers should be derived from what is explicitly stated in the statute, not what they may have intended to say. Interpretation is only necessary when following the literal meaning of the law would result in an impossible, absurd, or unjust outcome.
For instance, in the case of Republic v. Manalo (April 24, 2018), a Filipino wife obtained a valid divorce abroad, which allowed her foreigner husband to remarry. The question arose as to whether the Filipino wife could also remarry under Article 26 (2) of the Family Code, which states that if an alien spouse obtains a valid divorce abroad, the Filipino spouse is likewise allowed to remarry under Philippine law. The Supreme Court held that the plain meaning of Article 26 (2) only required a valid divorce obtained abroad and did not specify who initiated the divorce proceedings. The Court reasoned that it would be absurd to deny the Filipino spouse the right to remarry while the foreign spouse is allowed to do so. This decision reflects the principle of verba legis.
Now let’s move on to ratio legis et anima, which means the reason or spirit of the law. This principle was explained somewhat elaborately in League of Cities v. Comelec (Dec. 21, 2009) as follows: “A statute should be interpreted according to its spirit or intent because what is within the spirit is within the statute, even if it is not explicitly stated in the letter of the law. Conversely, what is within the letter but contrary to the spirit is not within the statute.” Please take a moment to read that quote from the Court and see if you can understand it. A simpler quote from another case, Naval v. Comelec (July 8, 2014), states that the true intention behind a law should be upheld even if it goes against the literal wording of the statute.
Take, for example, the case of Salvacion v. Central Bank (Aug. 21, 1997), which involved a Filipino minor who was detained and raped by an American tourist. The perpetrator escaped, causing a delay in the criminal case. The victim’s family filed a separate civil action for damages and sought to seize the perpetrator’s dollar account in a local bank. The bank argued that, under Republic Act No. 6426, dollar deposits are exempt from attachments and garnishments in order to encourage the inflow of foreign currency deposits. However, the Court observed that the law was enacted in a time of economic instability and was intended to incentivize foreign currency deposits. While the original intention of the law may have been good, it failed to anticipate the unjust and unequal consequences it would have. Thus, the Court ignored the letter of the law and declared it inapplicable to the case, ordering the bank to release the perpetrator’s dollar deposits to the rape victim.
Now we come back to the original question of how the MIF law and other laws should be interpreted: should it be based on verba legis or ratio legis? During my time as an incumbent, I relied on Article 10 of the Civil Code, which states that in cases of doubt in the interpretation or application of laws, it is presumed that the lawmaking body intended to uphold what is right and just. Therefore, I made my decisions based on the firm belief, after prayer and reflection, of achieving justice and righteousness.
In conclusion, I agree with both the Manalo and Salvacion decisions. Although they employed different methods of interpretation, verba legis and ratio legis, respectively, the Court ultimately upheld justice in both cases.
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