Political Law

United States vs Juan Pons

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G.R. No. L-11530 – 34 Phil. 729 – Political Law Constitutional Law – The Legislative Department – Legislative Process – Journal – Conclusiveness of the Journals

Juan Pons and Gabino Beliso were trading partners. On April 5, 1914, the steamer Lopez y Lopez arrived in Manila from Spain and it contained 25 barrels of wine. The said barrels of wine were delivered to Beliso. Beliso subsequently delivered 5 barrels to Pons’ house. On the other hand, the customs authorities noticed that the 25 barrels listed as wine on record were not delivered to any listed merchant (Beliso not being one). And so the customs officers conducted an investigation thereby discovering that the 25 barrels of wine actually contained tins of opium. Since the act of trading and dealing opium is against Act No. 2381 (An Act restricting the Use of Opium), Pons and Beliso were charged for illegally and fraudulently importing and introducing such contraband material to the Philippines. Pons appealed the sentence arguing that Act 2381 was approved while the Philippine Commission (Congress) was not in session. He said that his witnesses claim that the said law (when it was a bill) was passed/approved on 01 March 1914 while the special session of the Commission was adjourned at 12MN on February 28, 1914. Since this is the case, Act 2381 should be null and void.

ISSUE: Whether or not the SC must go beyond the recitals of the Journals to determine if Act 2381 was indeed made a law on February 28, 1914.

HELD: The SC looked into the Journals to ascertain the date of adjournment but the SC refused to go beyond the recitals in the legislative Journals. The said Journals are conclusive on the Court and to inquire into the veracity of the journals of the Philippine Legislature, when they are, as the SC have said, clear and explicit, would be to violate both the letter and the spirit of the organic laws by which the Philippine Government was brought into existence, to invade a coordinate and independent department of the Government, and to interfere with the legitimate powers and functions of the Legislature. The testimony of Pons’ witnesses cannot be given due weight against the conclusiveness of the Journals which is an act of the legislature. The journals say that the Legislature adjourned at 12 midnight on February 28, 1914. This settles the question, and the court did not err in declining to go beyond these journals. The SC passed upon the conclusiveness of the enrolled bill in this particular case.

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