People v.

Perfecto
G. R. No. 18463, October 04, 1922
MALCOLM, J.:

Facts
La Nacion, edited by Perfecto, published an article about the robbery/loss in the Senate of certain
documents that constituted records of testimony given by witnesses in the investigation of oil
companies. The article insinuated that the investigation was a mere comedy as the crime was the natural
effect of the environment of the Senate, wherein certain Senators owe their victory to electoral robbery
themselves. Senate Committee on Elections and Privileges adopted a Resolution authorizing the Senate
President to endorse to the Attorney General for corresponding action on the La Nacion Article. Perfecto
was charged for violation of Article 256 of the Spanish Penal Code for publishing the said article.

Issue
WoN Article 256 of the Spanish Penal Code is still effective?

Ruling:
No.
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. "Political" is here used to denominate the laws regulating the
relations sustained by the inhabitants to the sovereign.
Article 256 of the Penal Code was enacted by the Governor of Spain to protect the Spanish official
representatives of the King. However, with the occupation of the US, a change of sovereignty and
government followed, and a new government took effect in the Philippines. The provision which was
supposed to protect the Royal Crown of Spain became obsolete as the new US government did not
expressly adopt the rules of the old government.
As Article 256 of the Penal Code is contrary to the genus and fundamental principles of the American
character and system of government, the same was deemed abrogated and no longer in effect.