Harmonization of laws, Statutory Construction
“[E]ndeavor should be made to harmonize the provisions of a law or two laws so that each shall be effective. In order that one law may operate to repeal another law, the two laws must actually be inconsistent. The former must be so repugnant as to be irreconciliable with the latter act. (U.S. vs. Palacios, 33 Phil., 208.) Merely because a later enactment may relate to the same subject matter as that of an earlier statute is not of itself sufficient to cause an implied repeal of the latter, since the new law may be cumulative or a continuation of the old one.” (Statutory Construction, Crawford, p. 634.)’ (Valera v. Tuason, Jr., En Banc, G.R. No. L-1276, April 30, 1948, Per Tuason, J.)
“[A]ll parts of a statute are to be harmonized and reconciled so that effect may be given to each and every part thereof, and that conflicting intention in the same statute are never to be supposed or so regarded, unless forced upon the court by an unambiguous language.” (People v. Garcia, En Banc, G.R. No. L-2873, February 28, 1950, Per Tuason, J., citing 59 C. J., 999.)
“[The rule on harmonization of laws] applies in the construction of a statute and its amendment, both being read together as whole. “An amended act is ordinarily to be construed as if the original statute has been repealed, and a new and independent act in the amended form had been adopted in its stead; or, as frequently stated by the courts, so far as regards any action after the adoption of the amendment, as if the statute had been originally enacted in its amended form the amendment becomes a part of the original statute as if it had always been contained therein, unless such amendment involves the abrogation of contractual relations between the state and others. Where an amendment leaves certain portions of the original act unchanged, such portions are continued in force, with the same meaning and effect they had before the amendment. So where an amendatory act provides that an existing statute shall be amended to read as recited in the amendatory act, such portions of the existing law as are retained, either literally or substantially, are regarded as a continuation of the existing law, and not as a new enactment.” (59 C. J., 1096, 1097, cited in People v. Garcia, En Banc, G.R. No. L-2873, February 28, 1950, Per Tuason, J.)
“[A] statute must be interpreted, not only to be consistent with itself, but also to harmonize with other laws on the same subject matter, as to form a complete, coherent and intelligible system. The rule is expressed in the maxim, “interpretare et concordare legibus est optimus interpretandi,” or every statute must be so construed and harmonized with other statutes as to form a uniform system of jurisprudence.” (Philippine Economic Zone Authority v. Green Asia Construction & Development Corporation, G.R. No. 188866, October 19, 2011, Per Sereno, J.)
“A statute must be so construed as to harmonize and give effect to all its provisions whenever possible. The meaning of the law, it must be borne in mind, is not to be extracted from any single part, portion or section or from isolated words and phrases, clauses or sentences but from a general consideration or view of the act as a whole. Every part of the statute must be interpreted with reference to the context. This means that every part of the statute must be considered together with the other parts, and kept subservient to the general intent of the whole enactment, not separately and independently.” (Aisporna v. CA, G.R. No. L-39419, April 12, 1982, Per De Castro, J.)
