Tuesday, May 28, 2013

Manila Jockey Club v. Games and Amusement Board



Facts:
The authorized racing days specifically designated and distributed in Section 4 of RA 309 the basic law on horse racing in the Philippines amended by RA 983 are as follows: (1) Philippine Anti-TB Society for 12 Sundays, (2) PCSO - 6 Sundays (3) White Cross - 4 Sundays (4) Grand Derby Race of  PATS - 1 Sunday (5) Private Individuals and entities - 29 Sundays.
However, RA 1502 increased the sweepstakes draw and races of the PCSO from 6 to 12 Sundays, but without specifying the days on which they are to be run. To accommodate these additional races, GAB resolved to reduce the number of Sundays assigned to private individuals and entities by six.
Appellants protested that the said increase should be taken from the 12 Saturdays reserved to the President, for charitable relief OR should be assigned to any day of the week besides Sunday, Saturday and Legal Holiday.

Issues:
(1) Whether or not the petitioner has a vested right to the unreserved Sundays.
(2) Whether or not the additional sweepstakes races must be inserted in club races as debated in the House of Representatives in the voting of HB 5732/RA1502.

Held:
(1) No, the appellant has no vested right to the unreserved Sundays, or even to the 24 Saturdays (except holidays) because their holding on races for these days are merely permissive, subject to the licensing and determination by the GAB. When, therefore, RA 1502 was enacted increasing by 6 the sweepstakes draw and races but without specifying the days for holding them, the GAB had no alternative except to make room for the additional races, as it did, form among the only available racing days unreserved by any law - the Sundays on which the private individuals and entities have been permitted to hold their races, subject to licensing and determination by GAB.
(2) No. There is nothing in Republic Act No. 1502, as it was finally enacted, which would indicate that such an understanding on the part of these two members of the Lower House of Congress were received the sanction or conformity of their colleagues, for the law is absolutely devoid of any such indication.
In the interpretation of a legal document, especially a statute, unlike in the interpretation of an ordinary written document, it is not enough to obtain information to the intention or meaning of the author or authors, but also to see whether the intention or meaning has been expressed in such a way as to give it legal effect and validity. In short, the purpose of the inquiry, is not only to know what the author meant by the language he used, but also to see that the language used sufficiently expresses that meaning.
The language of Republic Act No. 1502 in authorizing the increase, clearly speaks of regular sweepstakes draws and races. If the intention of Congress were to authorize additional sweepstakes draws only which could, admittedly, be inserted in the club races, the law would not have included regular races; and since regular sweepstakes races were specifically authorized, and it would be confusing, inconvenient, if not impossible to mix these sweepstakes races with the regular club races all on the same day (and it has never been done before), the conclusion seems inevitable that the additional sweepstakes draws and races were intended to be held on a whole day, separate and apart from the club races.

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