G.R. No. 14129; July 31, 1962
PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. GUILLERMO MANANTAN, defendant-appellee.

FACTS

The Provincial Fiscal of Pangasinan filed an information charging Guillermo Manantan, a justice of the peace, with a violation of Section 54 of the Revised Election Code for allegedly engaging in partisan political activity. After a finding of probable cause and the commencement of trial, the defense moved to dismiss the information. The Court of First Instance initially denied the motion, holding that a justice of the peace was included within the prohibition. However, upon a second motion citing the Court of Appeals ruling in People vs. Macaraeg, the lower court reversed itself and dismissed the information, adopting the appellate court’s view that a justice of the peace was excluded from the enumeration in Section 54.

ISSUE

The sole legal issue for resolution is whether a justice of the peace is included among the public officers prohibited from engaging in partisan political activity under Section 54 of the Revised Election Code.

RULING

The Supreme Court reversed the order of dismissal and remanded the case for trial. The legal logic centers on statutory construction. Section 54 prohibits “No justice, judge, fiscal, treasurer, or assessor…” from aiding any candidate. The appellee argued that the omission of the specific phrase “justice of the peace,” which was present in the precursor statute (Section 449 of the Revised Administrative Code), revealed a legislative intent to exclude them. The Court rejected this argument. It held that the term “judge” in Section 54 is a generic and unqualified term intended to encompass all kinds of judges, including justices of the peace. The specific enumeration in the old Administrative Code was necessary because it separately listed “judge of the First Instance” and “justice of the peace.” Under the Revised Election Code, the broader term “judge” alone suffices to include both. The Court further supported this by defining a “judge” as a public officer clothed with judicial authority, a description fitting a justice of the peace. A review of the consistent legislative history from 1907 onwards showed a clear and unbroken policy to prohibit justices of the peace from partisan politics. The maxim expressio unius est exclusio alterius was found inapplicable, as no reasonable basis existed for singling out justices of the peace for exclusion from the prohibition, and applying the maxim would lead to a manifest injustice contrary to the statute’s clear intent.