SPRINGER v.

GOVERNMENT OF THE PHILIPPINE ISLANDS(1928)

Topic: The Philippine Independence Act/ Tydings-McDuffie Act(1934)

FACTS:

Acts of the Philippine Legislature creating a coal company and a bank, the stock of
which is largely owned by the Philippine government, that the power to vote the stock
shall be vested in a "Committee," and in a "Board of Control," each consisting of the
Governor-General, the President of the Senate, and the Speaker of the House of
Representatives.The majority of which in (277 U.S 189, 200) instance consisted of
officers and members of the Legislature, were invalid a being in conflict with the Organic
Act. That they do not fall within the authority of either of these two constitutes logical
ground for concluding that they do fall within that of the remaining one of the three
among which the powers of government are divided.

ISSUE:

1. Whether the duties devolved upon these members are vested by the Organic Act
in the Governor General?

RULING:

Yes, under the provisions of the amended act subscribed on behalf of the Philippine
Islands for substantially all of the capital stock. It provides:
“The voting power of all such stock owned by the government of the Philippine
Islands shall be vested exclusively in a committee, consisting of the Governor General,
the President of the Senate and the Speaker of the House of Representative. Article VI
Section 12 and Section 13 provides that, All Members of the Senate and the House of
the Representative shall, upon assumption of office, make a full disclosure of their
financial and business interests. They shall notify the House concerned of a potential
conflict of interest that may arise from the filing of a proposed legislation of which they
are authors.
Under the rule of Philippine Organic Act (1902) the act was a basic law for the Insular
Government that was enacted by the United States Congress on July1, 1902. The
approval of the act coincided with the official end of the Philippine- American war.

CONCLUSION:

It is therefore, that the instances in which Congress has devolved on persons not
executive officers the power to vote in nonstock corporations created for governmental
purposes lend no support to a construction of the Constitution which would justify
Congressional legislation like that here involved, considering the limited number of such
instances, the peculiar character of the institutions there dealt with, and the contrary
attitude of Congress towards governmentally owned or controlled stock corporations.