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People vs Que Po Lay (94 Phil 640) Facts : Appellant, Que Po Lay, was in possession of forei n e!

chan e consistin of "#$# %ollar chec&s an% "#$# 'oney or%ers a'ountin to a(out )*,000 faile% to sell the sa'e to the +entral ,an& throu h its a ents within one %ay followin the receipt of such forei n e!chan e as re-uire% (y +ircular .o# /0# 0he circular was issue% in the year 1949 an% was not pu(lishe% until .ove'(er 1921# Que Po Lay, was char e% (y the +ourt of First 3nstance of 4anila to suffer si! 'onths i'prison'ent, to pay a fine of P1,000 with su(si%iary i'prison'ent in case of insolvency, an% to pay the costs# 3ssue : 5hether or not circular no# /0 effective when Que Po Lay was convicte% three 'onths (efore circular /0 was pu(lishe%6 7el% : 0he pu(lication of circular no# /0 shoul% (e pu(lishe% (efore co'in to effective which Que Po Lay violate% (efore its pu(lication# 0he pu(lic 'ust (e infor'e% of sai% contents an% its penalties (efore the force an% effect to ta&e place# 7ence violation of Que Po Lay in the sai% circular no# is null or voi%#

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