Political Law J ournal Conclusiveness of the J ournals

Pons and Gabino Beliso were trading partners. On 5 Apr 1914, the steamer Lopez y Lopez arrived at Manila from Spain
and it contained 25 barrels of wine. The said barrels of wine were delivered to Beliso. Beliso subsequently delivered 5
barrels to Pons house. On the other hand, the customs authorities noticed that the said 25 barrels listed as wine on
record were not delivered to any listed merchant (Beliso not being one). And so the customs officers conducted an
investigation thereby discovering that the 25 barrels of wine actually contained tins of opium. Since the ct of trading and
dealing opium is against Act 2381, Pons and Beliso were charged for illegally and fraudulently importing and introducing
such contraband material to the Philippines. Pons appealed the sentence arguing that Act 2381 was not approved while
the Philippine Commission (Congress) was not in session. He said that his witnesses claim that the said law was
passed/approved on 01 March 1914 while the special session of the Commission was adjourned at 12MN on 28 Feb
1914. Since this is the case, Act 2381 should be null and void.
ISSUE: Whether or not the SC must go beyond the recitals of the Journals to determine if Act 2381 was indeed made a
as law on 28 Feb 1914.
HELD: The SC looked into the Journals to ascertain the date of adjournment but the SC refused to go beyond the recitals
in the legislative Journals. The said Journals are conclusive on the Court and to inquire into the veracity of the journals of
the Philippine Legislature, when they are, as the SC 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.
Pons witnesses cannot be given due weight against the conclusiveness of the Journals which is an act of the legislature.
The journals say that the Legislature adjourned at 12 midnight on February 28, 1914. This settles the question, and the
court did not err in declining to go behind these journals. The SC passed upon the conclusiveness of the enrolled bill in
this particular case.




The United States VS Juan Pons
GR NO. L-11530
ISSUE FACTS RULING

Petitioner: Juan Pons

Respondent: The United States

Issue:
1. W/N the court can look to
legislative journals as proof of
when the adjournment of
Legislature happened
2. W/N the court can go behind
the legislative journals to
determine the date of
adjournment




Gabino Beliso, Juan Pons and
Jacinto Lacarte were charged
with the crime of illegal
importation of Opium.
Juan Pons and Gabino Beliso
were tried separately. Both were
found guilty and both appealed
but Beliso later withdrew his
appeal.
Pons questioned the validity of
Act. 2381 and offered to prove
that the last day of the special
session of the Philippine
Legislature for 1914 was the
28th day of February; that Act
No. 2381, under which Pons
must be punished if found
guilty, was not passed or
approved on the 28th of
February but on March 1 of that
year; and that, therefore, the
same is null and void.

1. Yes. Section 275 of the Code of Civil
Procedure provides that the existence of
the "official acts of the legislative,
executive, and judicial departments of the
United States and of the Philippine Islands
... shall be judicially recognized by the
court without the introduction of proof

Official documents may be proved through:

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

2. The court did not go behind the legislative
journals when such journals are already
clear and explicit (about when Act No.
2381 was adjourned). to inquiry into the
veracity (accuracy) of the journals of the
Philippine Legislature, when they are, as
we have said, clear and explicit, would be
to interfere with the legitimate powers
and functions of the Legislature. The
journals already say that the Legislature
adjourned at 12 midnight on February 28,
1914.