CASE DIGEST

US vs. JUAN PONS

G.R. No. L-11530, August 12, 1916

Topic: Evidence of Due Enactment of Laws (Enrolled Bill Theory)

- To inquire into the veracity of the journals of the Philippine Legislature, when they are, as
we 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.

FACTS:

(1) This case is an appeal of Juan Pons, one of the defendants charged with illegal importation
of prohibited drug, opium, pursuant to Act No. 2381, An Act Prohibiting the Use of Opium,
to reverse the decision on the grounds that said Act is not valid.

(2) Juan Pons conspired with Gabino Beliso and Jacinto Lasarte of the illegal importation and
smuggling of opium stored in 25 barrels manifested as wine.

(3) The lower court charged them with crime of illegal importation, after Pons voluntarily
confessed on his participation in the smuggling of opium and attested that he and Beliso
had been parties in several opium transactions and shared profits from it.

(4) Petitioner filed an appeal and stated that the Government General’s proclamation is that
the last day of the special session of the Philippine Legislature is until February 28, 1914
only. The petitioner contend that Act No. 2381 was not passed or approved on February
28 but only on March 1, 1914. The petitioner alleged that the Assembly’s clock was stopped
at midnight of February 28 and left so until determination of the discussion of all pending
matters.

ISSUES:

(1) WON the Court can look over the legislative journals to determine the date of the
adjournment of a legislative session.

(2) WON the Court can go behind the legislative journals for the purpose of determining the
true date of adjournment.

HELD:

(1) AFFIRMATIVE.

Section 275 of the Code of Civil Procedure

“Official acts of the legislative, executive and the judicial departments of the US
and of the Philippine Islands xxx shall be judicially recognized by the court without the
introduction of proof.”

Section 313 of the Code of Civil Procedure

“Official documents may be proved as follows: xxx The proceedings of the

Philippine Commission, or of any legislative body that may be provided for the Philippine
Islands, or of Congress, by the journals of those bodies or of either house thereof, or by
published statutes or resolutions, or by copies certified by the clerk or secretary or printed
by their order: Provided, That in the case of Acts of the Philippine Commission or the
Philippine Legislature when there is in existence a copy signed by the presiding officers
 and the secretaries of said bodies, it shall be conclusive proof of the provisions of such Act
and of the due enactment thereof.”

(2) NEGATIVE.

The Court cannot look beyond the journals because it is already clear and explicit in the
journals.

A conference committee is generally not ruled by any limitation, but legislative custom
severely limits the freedom with which a new subject matter can be inserted into the
conference bill. But occasionally, a conference committee produces unexpected results
beyond its mandate. To which these deviations are within the authoritarian power of
conference committee.

(3) AFFIRMATIVE.

To inquire into the veracity of the journals of the Philippine Legislature, when they are, as
we 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.

CONCLUSION:

Court declined to go behind the journals of the Philippine Legislature.

Motion for Reconsideration is hereby dismissed. Act No. 2381 is valid and effective.