Upon the transfer of sovereignty from Spain to the United

States and later on from the United States to the Republic of

the Philippines, Article 14 of this Code of Commerce must be
deemed to have been abrogated because where there is
change of sovereignty, the political laws of the former
sovereign, whether compatible or not with those of the new
sovereign, are automatically abrogated, unless they are
expressly re-enacted by affirmative act of the new sovereign.

Likewise, in People vs. Perfecto (43 Phil. 887, 897 [1922]), this
Court stated that: “It is a general principle of the public law
that on acquisition of territory the previous political relations
of the ceded region are totally abrogated. ”
There appears no enabling or affirmative act that continued
the effectivity of the aforestated provision of the Code of
Commerce after the change of sovereignty from Spain to the
United States and then to the Republic of the Philippines.
Consequently, Article 14 of the Code of Commerce has no legal
and binding effect and cannot apply to the respondent, then
Judge of the Court of First Instance, now Associate Justice of
the Court of Appeals.