People v. Echavez G.R. Nos. L-47757-61. January 28, 1980

Facts: Petitioner Ello filed with the lower court against 16 persons charging them with squatting, as penalized in Presidential Decree 772. Respondent Echavez dismissed the case on the grounds that 1) the accused entered the land through stealth and strategy and not with the use of force, intimidation, or threat or taking advantage of the absence of the owner (as described in the Presidential Decree); and 2) under the rule of ejusdem genernis, the decree does not apply to the cultivation of a grazing land.

Issue: Whether or not Presidential Decree 771 penalizes squatting and similar acts also apply to agricultural lands

Held: No.

Ratio: The preamble shows that it was intended to apply to squatting in urban communities or particularly to illegal constructions in squatter areas. The complainant involves pasture lands in rural areas. The rule of ejusdem generis (of the same kind) does not apply to this case.

StatCon maxim: A preamble may restrict what otherwise appears to be a broad scope of a law.