Case Digests for Statutory Construction

G.R. No. 113092 September 1, 1994

MARTIN CENTENO, vs. HON. VICTORIA VILLALON-PORNILLOS

236 SCRA 197

Facts: The officers of a group of elderly men of a civic organization known as theSamahang Katandaan ng Nayon ng Tikay launched a fund drive for the purpose of renovating the chapel of Barrio Tikay, Malolos, Bulacan. Martin Centeno, the chairman of the group, approached Judge Adoracion G. Angeles, a resident of Tikay, and solicited from her a contribution of P1,500.00. It is admitted that the solicitation was made without a permit from the Department of Social Welfare and Development. As a consequence, an information was filed against Centeno, for violation of PD No. 1564 or the Solicitation Permit Law. Centeno filed a motion to quash the information on the ground that the facts alleged therein do not constitute an offense, claiming that PD No. 1564 only covers solicitations made for charitable or public welfare purposes, but not those made for a religious purpose such as the construction of a chapel.

Issue: Should the phrase "charitable purposes" be construed in its broadest sense so as to include a religious purpose?

How to Easily Digest a Case

TIPS ON DIGESTING CASES: You can never escape digesting cases in the College of Law. The objective in digesting cases is to discover how the law was applied. Your professor is less interested in the brilliancy of the lawyer or the parties involved or how they won or lost their case. What matters is how the Supreme Court resolved the issues.

1. DO NOT DIGEST UNLESS YOU KNOW THE CODAL PROVISION. It's a total waste of time. On the contrary, if you know what the law requires, it is easy to determine if the parties obeyed or disobeyed the law. The Court always sides with the party who obeyed the law.

2. DO NOT DIGEST CASES SINGLY. Groups of cases must be digested together because they all apply the same law - sometimes in contrasting manner. Spend the most time thoroughly digesting the first in a batch of cases. Succeeding cases will simply re-apply the same principle. However, look out for reversals of rulings.