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Legal Interpretation in US v. Hart

The document discusses two separate court cases. The first case involves respondents who were caught in a gambling house. The court found that the relevant statute should not be interpreted based solely on punctuation, and that if the respondents had visible means of support, they could not be convicted under the statute. The second case involves a will made in Manila by a US citizen. The court held that Section 636 of the civil code, which governs wills made by aliens, applied to the US citizen as well, as an epigraph or heading cannot limit the scope defined in the body of the statute. Punctuation and capitalization are not controlling in statutory interpretation.

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80 views2 pages

Legal Interpretation in US v. Hart

The document discusses two separate court cases. The first case involves respondents who were caught in a gambling house. The court found that the relevant statute should not be interpreted based solely on punctuation, and that if the respondents had visible means of support, they could not be convicted under the statute. The second case involves a will made in Manila by a US citizen. The court held that Section 636 of the civil code, which governs wills made by aliens, applied to the US citizen as well, as an epigraph or heading cannot limit the scope defined in the body of the statute. Punctuation and capitalization are not controlling in statutory interpretation.

Uploaded by

KrizzaShayneRamosArquero
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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US v. Hart, et al. 26 Phil.

146

FACTS: Respondent was caught in a gambling house and was penalized under Act

No. 519 which punishes “every person found loitering about saloons or dram shops

or gambling houses, or tramping or straying through the country without visible

means of support”. The said portion of the law is divided into two parts, separated

by the comma, separating those caught in gambling houses and those straying

through the country without means of support. Though it was proven that Hart and

the other Defendants had “visible means of support”, it was under the first part of

the portion of law for which they were charged with. The prosecution persisted that

the phrase “without visible means of support” was in connection to the second part

of the said portion of Act No. 519, therefore was not a viable defense. ISSUE: How

should the provision be interpreted? HELD: The construction of a statute should be

based upon something more substantial than mere punctuation. If the punctuation

gives it a meaning which is reasonable and is in apparent accord with legislative

will, it may be as an additional argument for adopting the literal meaning of the

words in the statute as thus punctuated. An argument based on punctuations alone

is not conclusive and the court will not hesitate to change the punctuation when

necessary to give the act the effect intended by the legislature, disregarding

superfluous and incorrect punctuation marks, or inserting others when necessary.

Inasmuch as defendant had, “visible means of support” and that the absence of

such was necessary for the conviction for gambling and loitering in saloons and

gambling houses, defendants are acquitted. LATIN MAXIM: 11e, 33

FACTS: Petitioner was a native of Sweden and a naturalized citizen of the United

States but died and left a will in Manila. Sec. 636 of the Code of the Civil Procedure

states “Will made here by an alien—will made within the Philippine Islands by a

citizen or subject of another state or country, which is executed in accordance with


the law of the state or country of which he is a citizen or subject, and which might

be proved, allowed by the law of his own state or country, may be proved, allowed

and recorded in the Philippine Islands and shall have the same effect as if executed

according to the laws of these Islands.” The will of Johnson was probated and

allowed in the lower court, but Petitioner contends that Sec. 636 is applicable only

to wills of aliens; and in this connection, attention is directed to the fact that the

epigraph of this section speaks only of the will made here by an alien and to further

fact that the word “state” in the body of the section is not capitalized. ISSUE: W/N

the will of Petitioner, a citizen of the U.S and therefore an alien, is covered by Sec.

636. HELD: The fact that the words “state” and “country” are not capitalized does

not mean that the United States is excluded from the phrase “another state or

country”. It is a rule of hermeneutics that punctuation and capitalization are aids of

low degree in interpreting the language of a statute and can never control against

the intelligible meaning of the written words. The epigraph, or heading, of a section

being nothing more than a convenient index to the contents of the provision,

cannot have the effect of limiting the operative words contained in the body of the

text. Petitioner, being a US citizen, thus an alien, is covered by Sec. 636. The will

duly probated. LATIN MAXIM: 24a, 25a, 26, 37, 42a, 48

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