FACTS:
President Ferdinand Marcos issued Proclamation No. 208 amending Proclamation 423 which excludes certain area of Fort Bonifacio for a national shrine which will be known as Libingan ng mga Bayani which is under the administration of the respondents. Again, President Marcos issued Proclamation that excluded the barangays of Lower Bicutan, Upper Bicutan and Signal Village and a handwritten addendum which includes Western Bicutan for the disposition of the area. The proclamation was published in the Official Gazette without the handwritten addendum. Demolition of illegal structures was conducted which caused the petitioners to file before Commission on Settlement of Land Problems (COSLAP) for reclassification. COSLAP ruled that the handwritten addendum of President Marcos was not published thus the areas occupied by the petitioners are in question alienable and disposable.
ISSUE: Whether the handwritten addendum of President Marcos have the force and effect of law though it was not included in the publication
RULING:
No. The publication must be in full or it is no publication at all since its purpose is to inform the public of the contents of the laws. Pursuant to Article 2 of the Civil Code, the requirement of publication is indispensable to give effect to the law, unless the law itself has otherwise provided. Though Proclamation No. 2476 was published in an Official Gazette, the handwritten addendum of President Marcos declaring the Western Bicutan as alienable and disposable was not included. Therefore, without publication, the handwritten addendum of President Marcos never had any legal force and effect.
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