dissenting.
The principal opinion acts as if the Missouri precedents — admittedly on all fours with this case — are trivial. In fact, the principal opinion is contrary to a long line of cases, to key concepts of Missouri administrative law, and to the rules of statutory construction.
I. History of “Filing” Rules in Worker’s Compensation Cases
Shortly after the enactment of the Worker’s Compensation law, the Kansas City *344Court of Appeals, in 1931, reviewed the predecessor to § 287.480, and held that an application for review “received” by the commission after the statutory period for appeal may be “refused properly because untimely.” Waring v. Metropolitan Life Ins. Co., 39 S.W.2d 418, 422 (Mo.App.1931). Also in 1931, the St. Louis Court of Appeals held that “an application for a rehearing within the time fixed by statute and a final award thereon by the commission, is necessary and a prerequisite to a right to appeal to the circuit court.” State ex rel. Kenney v. Missouri Workmen’s Comp. Comm’n, 40 S.W.2d 503, 505 (Mo.App.1931).
Against this background, in 1958, the St. Louis Court of Appeals held that mailing the appeal on the deadline day — with receipt on the next day — did not give the commission jurisdiction to review the appeal. Tabb v. McGinley, 313 S.W.2d 745, 746-48 (Mo.App.1958). The Tabb case relied on an analogous administrative law decision by this Court, State ex rel. Alton Ry. Co. v. Public Service Comm’n, 155 S.W.2d 149, 154 (Mo.1941). In 1968, the St. Louis Court of Appeals held that, where the envelope was “postmarked” within the statutory period, but received after the statutory period, the commission had no jurisdiction. Hoelscher v. Sel-Mor Garment Co., 430 S.W.2d 745, 746-48 (Mo.App. 1968).
In 1974, the General Assembly enacted the second sentence of § 287.480: “Any notice of appeal, application or other paper required under this law to be filed with the division or the commission shall, when mailed to and received by the division or the commission, be deemed to be filed as of the date endorsed by the United States Post Office on the envelope or container in which such paper is received.”
The key to the principal opinion is that the Worker’s Compensation Act shall be liberally construed. (Maj. op. at 341-342). This liberal rule of construction, however, means that questions of jurisdiction shall be resolved in favor of the commission: “However, the provisions of the Worker’s Compensation statute are to be liberally construed with a view to the public welfare, § 287.800, RSMo 1969, so that where a question of jurisdiction is in doubt it should be held to be in favor of the commission.” Ringeisen v. Insulation Services, Inc., 539 S.W.2d 621, 625-26 (Mo.App.1976). See also Patterson v. St. Louis University Hospital, 780 S.W.2d 106, 108 (Mo.App.1989); Knuckles v. Apex Industries, Inc., 762 S.W.2d 542, 543 (Mo.App.1988).
The principal opinion errs in applying the standard for the content of a notice of appeal to the jurisdictional timeliness of a notice of appeal. See Graves v. O.F. Elliott, Inc., 197 S.W.2d 977, 979 (Mo. banc 1946): “We hold that the only jurisdictional requirement for such an appeal is the timely filing of a notice of appeal which fairly shows that the appellant desires to appeal from the final award in his case....”
It is clear that the 1974 amendment changed the date on which an appeal is deemed filed from the date of receipt to the date postmarked. Long v. City of Hannibal, 670 S.W.2d 567, 569 (Mo.App.1984). In view of this history, the Court of Appeals, Western District in Penn Valley Management Inc. v. Robertson, 724 S.W.2d 661 (Mo.App.1987), consistently and logically held that a private postage meter imprint is not an endorsement on the envelope of the mailing date by the post office.
In sum, the court of appeals has consistently interpreted the phrase “endorsed by the United States Post Office on the envelope or container in which such papers are received” as meaning a postmark. See Penn Valley, 724 S.W.2d at 663-64; Patterson, 780 S.W.2d at 108. The commission, as apparent from this case, has applied this rule consistently — and equally to employers and employees. The principal opinion changes the rule and permits postage meter imprints to be used to prove the date of filing.
II. Practice of Missouri Administrative Agencies
This result is contrary to key principles of Missouri administrative law. The main administrative tribunal, the Administrative *345Hearing Commission, has accepted as proof of mailing only registered mail since 1980. See § 621.205 RSMo 1986. In 1991, the General Assembly changed the law to allow certified mail also. S.B. 283, Vernon’s Mo. Legis. Service 580, 581 (1991) (restoring the pre-1980 requirement altered by the original enactment of § 621.205).
Even a postmark does not qualify to prove date of filing at the Administrative Hearing Commission. See, e.g., Evergreen Lawn Service, Inc. v. Director of Revenue, 685 S.W.2d 829 (Mo. banc 1985) (deadline for filing in person is thirtieth day; if office is closed that day, deadline is next day that the office is open); Springfield Park Central Hospital v. Director of Revenue, 643 S.W.2d 599 (Mo.1983) (filing by regular mail does not extend deadline by three days; pleading must be received in office by thirtieth day); City of St. Louis v. Director of Revenue, 654 S.W.2d 118 (Mo.App.1983) (filing by express mail must be received in office by thirtieth day); Cardinal Glennon Memorial Hospital Coffee Shop v. Director of Revenue, 624 S.W.2d 115 (Mo.App.1981) (filing by mail received on the thirty-second day because the office was closed on the thirtieth day was late).
Several other statutes require that materials are deemed filed with a state agency when received unless sent by registered or certified mail. A declaration of candidacy for elected office must be filed in person with two exceptions for registered or certified mail. § 115.355 RSMo 1986. Pleadings with the State Tax Commission are deemed filed at the time of mailing only if sent by registered or certified mail. § 138.433 RSMo 1986.
Several tax statutes deem documents filed as of the date postmarked on the envelope or other container in which the documents are sent. See § 142.140 RSMo 1986 (filing of monthly report by distributors — gas tax); § 142.517 RSMo 1986 (filing of monthly report by licensees — diesel tax); § 143.851 RSMo 1986 (filing of all documents related to income tax); cf. § 130.046 RSMo Supp.1990 (campaign finance reports). Neither appellant nor the principal opinion have cited any state agency that accepts the date stamped by a postal meter as the date of filing.
Missouri administrative law, thus, requires that some government official certify that a filing was either sent to or received by the agency in a timely fashion. True, the statute governing appeals to the Labor and Industrial Relations Commission, like the statutes for some other agencies, consider a simple postmark to be proof of timely filing, rather than requiring that the pleading be sent by certified or registered mail. This difference does not logically indicate a legislative intent to allow a party to self-certify the date of filing. The most logical reading of this difference is that an appeal may be filed at reduced cost with the LIRC by allowing a simple postmark to certify the date.
III. Rules of Construction
The principal opinion notes the multiple “dictionary” meanings of the word “endorse” and proceeds to apply the rule of construction that remedial statutes are to be liberally construed, (Op. at 340). Rules of construction must be applied as a comprehensive whole rather than independent rules analyzing words out of context. In addition, the rule providing for liberal construction of remedial statutes and strict construction of penal statutes only applies when there are, at least, two plausible interpretations under the other rules of construction. Cf. Metro Auto Auction v. Director of Revenue, 707 S.W.2d 397, 404-05 (Mo. banc 1986) (rule of liberal construction inapplicable when language of statute is not ambiguous); State ex rel. LeFevre v. Stubbs, 642 S.W.2d 103, 106 (Mo. banc 1982) (rules of liberal construction apply to remedial statutes “provided such interpretation is not inconsistent with the language used ... resolving all reasonable doubts in favor of applicability of the statute to the particular case”); 2A Sutherland Stat. Const. § 58.05 (4th ed. 1984) (rules of strict or liberal construction have no application where the language of the statute is clear).
The main rule of construction is that a word in a statutory sentence, like a word in any other sentence, is read in the context *346of that statute to determine its meaning.1 In this case, the provision states that an appeal shall be deemed filed “as of the date endorsed by the United States Post Office on the envelope.... ” While “endorse” can mean either approving something or placing a stamp/signature on something, the remainder of the statute containing “endorsed” provides the context that determines its meaning.
In § 287.480, the sentence shows both who must endorse the date and where that endorsement goes. “[Ejndorsed” is the beginning of a phrase modifying date. A major assumption of English grammar is that adjectives and adverbs modify the term most closely preceding them. This assumption is stated as the “last clear antecedent” rule: “relative and qualifying words, phrases, or clauses are to be applied to the words or phrase immediately preceding and are not to be construed as extending to or including others more remote.” Rothschild v. State Tax Comm’n, 762 S.W.2d 35, 37 (Mo. banc 1988).
The sentence structure clearly indicates that “on the envelope” is adverbial, modifies “endorse,” and is not an adjective modifying the remote word “date.” If the phrase “on the envelope” were an adjective, as the principal opinion construes it, “endorsed by the United States Post Office” would have to be set off by commas (i.e., “date, endorsed by the United States Post Office, on the envelope”). Because there are no commas, “endorsed” cannot mean “approved” in § 287.480. Therefore, the liberal rule of construction cited by the principal opinion is irrelevant as the statute has a “plain meaning.”
Despite the assertions of the principal opinion to the contrary, the language of § 287.480 is clear and unambiguous. As such, any change should come from the General Assembly and not from this Court.
IV. Practical Problems with the Principal Opinion
The principal opinion relies upon postal regulations and postal duties. In the area of postal administrative regularity, Missouri courts have consistently refused to speculate on the regular flow of mail. Hoelscher v. Sel-Mor Garment Co., 430 S.W.2d at 748. The principal opinion goes one step beyond, and takes judicial notice of intricate postal inspection matters.
The principal opinion’s rule is a bonus to sophisticates who own postage meters and can affix the postage meter imprint but then not deposit the appeal until a later date. At the same time, the unsophisticated may deposit the appeal after 5:00 p.m. and receive a postmark days later. The principal opinion encourages sophisticated comer-cutting, but penalizes honest ignorance.
Even assuming a perfect world, the principal opinion ignores some crucial provisions of the Domestic Mail Manual (DMM). Under these provisions, a person with a postal meter can use the prior day’s date if the letter or package is deposited in the mail before the first collection of the day. § 144.471(b) DMM. When metered mail is inspected, a postmark with the prior day’s date is not “erroneous” if the letter is found in the first collection of the day. § 144.517 DMM.
Even if there were no cheating by the party with the postage meter, the principal opinion’s rule still gives the parties owning them an advantage. The party who files by personal delivery has a deadline of, typically, 5 p.m. on the deadline date. The party who files by mail has a deadline of approximately the same time (depending upon when the time of the last mail pickup). The party who files by metered mail, however, is given a deadline of, at least, 11:59 p.m.
*347A French philosopher once said: “The law, in its majestic equality, forbids the rich as well the poor to sleep under bridges, to beg in the streets, and to steal bread.”2 In this case, according to the principal opinion, the law, in its majestic equality, allows the poor as well as the rich to use postal meters. The statute, however, intends that the working poor, and small-business owners, can inexpensively and effectively appeal to the LIRC. In the absence of clear legislative intent, the statute should not be interpreted to give an advantage to those who are wily and resourceful.
For these reasons, I dissent.
. This rule is stated in many different ways: (1) as whole statute interpretation, 2A Sutherland Stat. Const. § 46.05 (4th ed. 1984) (“It is always an unsafe way of construing a statute ... to divide it by a process of etymological dissection, and to separate words and then apply to each, thus separated from its context, some particular definition given by lexicographers...."; (2) as the maxim of noscitur a sociis (or associated words), id. at § 47.16 ("the meaning of doubtful words may be determined by reference to their relationship with other associated words and phrases”); or (3) as the rule of common meaning, id. at § 47.28.
. Bartlett’s Familiar Quotations 802 (14th ed. 1968) (quotation from Anatole France).