Arguments

The intention of the lawmakers is not to apply the RA 9009 to Respondent

Municipalities
Article 4 of Civil Code provides that, laws shall have no retroactive
effect, unless the contrary is provided, for it is said that the law looks to the
future and has no retroactive effect unless the legislature may have given
that effect to some legal provisions, and that statutes are to be construed as
having only prospective operation , unless the purpose and intention of
legislature to give them a retrospective effect expressly declared or is
necessarily implied from language used, and that, in case of doubt, the same
must be resolved against the retrospective effect .( Buyco v. PNB, 2 SCRA
682;Lazaro v. Commissioner of Customs, 17 SCRA 37).

The Court stressed that Congress clearly intended that the local
government units covered by the Cityhood Laws be exempted from the
coverage of RA 9009, which imposes a higher income requirement of PhP100
million for the creation of cities.
The Court reiterated that while RA 9009 was being deliberated upon,
the Congress was well aware of the pendency of conversion bills of several
municipalities, including those covered by the Cityhood Laws. It pointed out
that RA 9009 took effect on June 30, 2001, when the 12th Congress was
incipient.

By

reason

of

the

clear

legislative

intent

to

exempt

the

municipalities covered by the conversion bills pending during the 11th

Congress, the House of Representatives adopted Joint Resolution No. 29
entitled Joint Resolution to Exempt Certain Municipalities Embodied in Bills
Filed in Congress before June 30, 2001 from the coverage of Republic Act No.
9009. However, the Senate failed to act on the said Joint Resolution. Even so,
the House readopted Joint Resolution No. 29 as Joint Resolution No. 1 during
the 12th Congress, and forwarded the same for approval to the Senate,
which again failed to prove it. Eventually, the conversion bills of respondents
were individually filed in the Lower House and were all unanimously and
favorably voted upon. When forwarded to the Senate, the bills were also
unanimously approved. The acts of both Chambers of Congress show that
the exemption clauses ultimately incorporated in the Cityhood Laws are but
the express articulations of the clear legislative intent to exempt the
respondents, without exception, from the coverage of RA No. 9009. Thereby,
RA 9009, and, by necessity, the LCG, were amended, not by repeal but by
way of the express exemptions being embodied in the exemption clauses.
(GR No. 176951, League of City of the Philippines v. COMELEC; GR No. 177499, League of
City of the Philippines v. COMELEC: GR No. 178056, League of City of the Philippines v.
COMELEC, April 12, 2011).

In Statutory Construction, legislative intent is the vital part, the

essence of the law. (Torres v. Limjap, 56 Phil. 141 (1931)) The intent of the
legislature is the law, and the key to, and the controlling factor in, its
construction or interpretation. (U.S. v. Tamparong, 31 Phil. 321 (1915)) Intent is the
spirit which gives life to the legislative enactment. It must be enforced when
ascertained, although it may not be consistent with the strict letter of the
statute. Courts will not follow the letter of the statute when it leads away
from the true intent of the legislature and to conclusions inconsistent with
the general purpose of the act. (Torres v. Limjap, 56 Phil. 141 (1931)) Hence, where
a statute susceptible of more than one construction that construction should
be adopted which will most tend to give effect to the manifest intent of the
legislature. (U.S. v. Toribio, 15 Phil.85 (1910)). This was couple also in the legal
maxim ratio legis est anima which means the spirit rather than the letter of
the law.
The cardinal rule in the interpretation of all laws is to ascertain, and
give effect to, the intent of the law. (Macondray &Co. v. Eustaquio, 64 Phil. 446
(1937)).

Hence, all rules of the construction or interpretation have for their

sole object the ascertainment of the true intent of the legislature. (Tanada v.
Cuenco, 103 Phil. 1051 (1957 )).

Moreover, the object or purpose of all judicial

interpretation of the statute is to determine legislative intent what intention

conveyed either expressly or impliedly, by the language used, so far as it is
necessary for ascertaining whether particular case or state of facts
presented to the court comes within it. (Salaysay v. Castro, 98 Phil.364 (1936))
Thus, in the abovementioned arguments, Congress clearly stated that
the intention of the lawmakers is to exempt respondent municipalities from
such a belatedly imposed modified income requirement in order to uphold its
higher calling of putting flesh and blood to the very intent and thrust of the
LGC, which is countryside development and autonomy, especially accounting
for these municipalities as engines for economic growth in their respective
provinces.( League of Cities of the Philippines V. COMELEC G.R. No. 176951 : February 15,
2011)