People v. Valensoy
REITERATIONFacts
The Antecedents: Valeriano Valensoy y Masa was charged with a violation of Section 26, Act No. 1780, for the concealment of a bolo, described as a deadly weapon, about his person. Procedural History: The defendant moved to quash the information, arguing that Section 26 of Act No. 1780 violated the constitutional prohibition against bills embracing more than one subject not expressed in the title. The trial court denied this motion. Subsequently, the defendant admitted the factual allegations but maintained his innocence based on the legal grounds previously raised. The trial court found him guilty and imposed a fine of P10, with subsidiary imprisonment in case of insolvency. The Appeal: The defendant appealed the decision of the trial court, reiterating the grounds for his motion to quash, specifically the alleged unconstitutionality of Section 26 of Act No. 1780 in relation to the title of the Act and the constitutional provision on the one-subject rule.
Issue(s)
Whether Section 26 of Act No. 1780, which prohibits the concealment of deadly weapons other than firearms, violates the constitutional requirement that a law shall embrace only one subject expressed in its title. Whether a law validly enacted under the Act of Congress of July 1, 1902, becomes invalid upon the effectivity of the 1935 Constitution if it does not conform to the broader one-subject rule applicable to all bills under the new Constitution.
Ruling
The Supreme Court affirmed the judgment of the trial court, finding the defendant guilty as charged. The Court held that Section 26 of Act No. 1780 is constitutional and did not become inoperative upon the adoption of the 1935 Constitution.
Ratio Decidendi
On Issue 1: The Court held that Section 26 of Act No. 1780 does not violate the constitutional provision requiring a bill to embrace only one subject expressed in its title. At the time of the enactment of Act No. 1780 on October 12, 1907, the applicable constitutional prohibition, found in Section 5 of the Act of Congress of July 1, 1902, referred only to private or local bills. The inclusion of the prohibition against concealing deadly weapons, while the title of the Act primarily dealt with firearms, was considered germane to the overall subject of regulating dangerous weapons. Therefore, the law was validly enacted under the prevailing constitutional framework at that time. On Issue 2: The Court ruled that Act No. 1780, having been validly passed under the Act of Congress of July 1, 1902, did not become repugnant to or repealed by the 1935 Constitution. The constitutional provision in the 1935 Constitution stating that "No bill which may be enacted into law shall embrace more than one subject which shall be expressed in the title of the bill" applies to bills to be enacted thereafter and not to laws already in force. Furthermore, Article XVI, Section 2 of the 1935 Constitution explicitly provides that all laws of the Philippine Islands shall continue in force until the inauguration of the Commonwealth and thereafter, unless inconsistent with the Constitution. Since Section 26 of Act No. 1780 was not inconsistent with the 1935 Constitution, it remained operative.
Main Doctrine
A law validly enacted under the provisions of the Act of Congress of July 1, 1902, which prohibited more than one subject not expressed in the title only for private or local bills, remains valid and operative upon the effectivity of the 1935 Constitution, provided that its provisions are not inconsistent with the new Constitution. This continuity of laws is further supported by Article XVI, Section 2 of the 1935 Constitution, which explicitly states that all laws of the Philippine Islands shall continue in force until the inauguration of the Commonwealth and thereafter unless inconsistent with the Constitution.