The phrase "several days after a session" as used in Section 18, subdivision 2 of Act No. 2935, governing appropriations for "supplementary force" in the Legislature, cannot be legally construed to cover a period of eighty-two days after the adjournment of the legislative session; consequently, temporary employees rendering services during such an extended period are not legally employed under that specific appropriation and have no clear legal right to compensation.

The petitioner was employed as a "temporary clerk" in the Philippine Senate. Following the adjournment of the legislative session, his services continued for an extended period. A dispute arose when the Insular Auditor refused to approve the payment warrant for services rendered significantly later than the session's close, citing limitations in the relevant appropriation act regarding temporary legislative employees. This case arose as a "test case" potentially affecting numerous similarly situated employees.

• Petitioner Magdaleno Riel was appointed as a "temporary clerk" in the office of the Secretary of the Philippine Senate on September 1, 1925, with a salary of P40 per month.
• The Philippine Legislature closed its last session on November 9, 1925.
• Petitioner was paid his salary up to and including January 31, 1926.
• Petitioner continued performing his duties, allegedly "to the present time" (time of petition filing).
• A warrant for P20 was issued in favor of the petitioner for services rendered from February 1 to 14, 1926.
• The respondent, Insular Auditor Ben F. Wright, refused to approve and sign the warrant.
• The period for which payment was claimed (February 1-14, 1926) began eighty-two days after the legislative session ended.
• On December 31, 1925, the Secretary of the Senate revoked a prior notice (from Dec 7, 1925, indicating services would be dispensed with) and required the petitioner "to continue rendering services until further order."
• The Auditor contended that funds for petitioner's position were governed by Act No. 2935, Sec. 18(2), covering "employees rendering service before, during, and several days after a session."
• The Auditor asserted that petitioner's services were unnecessary after February 1, 1926, due to the presence of numerous permanent Senate employees.

• Petitioner was duly appointed and performed the services for which the warrant was issued (Feb 1-14, 1926).
• The respondent Auditor has a plain legal duty to approve the warrant, which he unjustly refuses to do.
• Sufficient funds were available in the Insular Treasury for the payment of the warrant.
• Petitioner has no other plain, speedy, or adequate remedy in the ordinary course of law.
• Section 18 of Act No. 2935 is unconstitutional if interpreted to deny payment, as it allegedly embraces two subjects, one not expressed in the Act's title.
• Petitioner was explicitly required by the Senate Secretary to continue rendering services "until further order" after the session.

• The Supreme Court lacks jurisdiction over the subject matter and the official acts of the Insular Auditor, whose powers are claimed to be identical to the U.S. Comptroller, whose decisions are not reviewable by courts.
• Petitioner has another plain, speedy, and adequate remedy.
• Petitioner's employment falls under "supplementary force" in Act No. 2935, limited to "several days after a session."
• The period claimed (starting 82 days post-session) is far beyond "several days after a session."
• Petitioner's services, along with those of similar employees, have been unnecessary since February 1, 1926.
• The Senate Committee on Accounts Chairman was advised on January 29, 1926, that payment would be refused.

• Does the Supreme Court have jurisdiction to issue a writ of mandamus against the Insular Auditor to compel the signing of a salary warrant?
• Does the phrase "several days after a session" in Act No. 2935, Section 18(2) encompass services rendered eighty-two days after the adjournment of the Legislature?
• Is Section 18 of Act No. 2935 unconstitutional?
• Does the petitioner have a clear legal right to the salary claimed for the period February 1 to 14, 1926, compelling the issuance of a writ of mandamus?

• The Supreme Court held that it possesses jurisdiction over the Insular Auditor, distinguishing his powers from the U.S. Comptroller by noting that Philippine law explicitly limited the finality of the Auditor's decisions to the "executive branch," thereby implying judicial review is permissible.
• The Court ruled that the phrase "several days after a session" cannot be construed to mean or apply to a period of eighty-two days; the Legislature intended a limited timeframe for supplementary force after adjournment.
• The Court found Section 18 of Act No. 2935 to be constitutional, holding that its provisions regarding legislative appropriations were germane to the overall purpose of the Appropriation Act.
• Since the petitioner's services from February 1-14, 1926, fell outside the period legally covered by the appropriation for "supplementary force" (i.e., beyond "several days after a session"), he had no clear legal right to the compensation claimed.
• The writ of mandamus was denied because the petitioner failed to establish a clear legal right to have the warrant approved.

• Mandamus: Defined as a writ issued to compel the performance of a ministerial duty when the petitioner has a clear legal right to the act sought. It was applied here but denied because the petitioner failed to demonstrate a clear legal right to payment, as his services fell outside the legally authorized appropriation period.
• Statutory Construction: Defined as the process of interpreting the meaning and intent of legislation. The Court applied this by strictly construing the phrase "several days after a session" in Act No. 2935, refusing to extend its meaning to eighty-two days, based on the presumed legislative intent and common understanding of the words. The Court also construed Act No. 2935 as a whole to determine that Section 18 was germane to the Act's title and purpose, upholding its constitutionality.
• Jurisdiction over Insular Auditor: Defined as the court's authority to review the decisions of the Insular Auditor. The Court affirmed its jurisdiction, distinguishing from the finality of the U.S. Comptroller's decisions by referencing the specific Philippine statute (implicitly, the Jones Law or related organic acts) which stated the Auditor's decisions were binding on the "executive branch," thus not precluding judicial review by other branches.
• Separation of Powers (Implied): The principle that governmental powers are divided among distinct branches (legislative, executive, judicial). It was invoked implicitly when the Court dismissed the Auditor's argument about the necessity of legislative employees, stating, "It is not for the Insular Auditor to say how many employees the Legislature should have or the compensation which they would receive. That is a matter within the peculiar province of the Legislature..."

• "It is not for the Insular Auditor to say how many employees the Legislature should have or the compensation which they would receive. That is a matter within the peculiar province of the Legislature and for which its members are responsible to their constituents."
• "No authority has been cited, and none will ever be found, construing the words 'several days' to cover and include a period of eighty-two days."
• "But we do hold that, as to the 'supplementary force,' the words [several days after a session] cannot be construed to mean or apply to a period of eighty-two days 'after a session.' Giving them this construction, it follows that the petitioner has no legal right to compensation for the services in question."
• "...the law here expressly says that the decisions of the Insular Auditor are binding upon the 'executive branch' of the government. The fact that the law specifically says that his decisions are binding upon the 'executive branch' of the government, under all rules of statutory construction, clearly implies and carries with it that his decisions are binding upon the executive branch only, and that they are not binding upon any other branch of the government."

• Ynchausti & Co. v. Wright (47 Phil. 866): Cited to support the Court's assertion of jurisdiction over the Insular Auditor. The Ynchausti case established the principle that under the existing law, the decisions of the Insular Auditor were binding only upon the executive branch, not all branches of government, thus differentiating the Auditor's authority from that of the U.S. Comptroller and confirming the judiciary's power to review the Auditor's decisions when appropriate.

• Act No. 2935, Section 18: Cited as the governing law establishing rules for legislative appropriations.
• Act No. 2935, Section 18, subdivision 2: Specifically cited as defining the scope and availability of appropriations for "supplementary force," limiting payment to employees rendering service "before, during, and several days after a session."
• Administrative Code, Section 100: Mentioned within the text of Act No. 2935, Section 18(2) regarding the appointment of officers.