G.R. No. 43290 - People vs. Linsangan

Ambrosio Linsangan (Appellant) was prosecuted for nonpayment of the cedula or poll tax under section 1439, in connection with section 2718, of the Revised Administrative Code of the Philippine Islands.
After trial, Appellant was sentenced to imprisonment for five days and required to pay the costs.

Appellant appealed the judgment, arguing that sections 1439 and 2718 of the Revised Administrative Code were unconstitutional and void.
Section 1439 specified who must pay the cedula tax.
Section 2718 authorized the provincial treasurer to prosecute and imprison anyone who failed to pay the cedula tax within fifteen days after June 1st each year, imposing imprisonment of five days per unpaid cedula.

The case was tried and decided before the Constitution of the Philippines took effect.
While the appeal was pending, the Constitution became effective, specifically Section 1, Clause 12, Article III, which prohibits imprisonment for debt or nonpayment of a poll tax.
Appellant argued that his imprisonment conflicted with this constitutional provision.

The Philippine Constitution was drafted pursuant to the Tydings-McDuffie Law (Act of Congress March 24, 1934), which authorized Filipinos to adopt a constitution subject to certain conditions.
The process included drafting by a Constitutional Convention (which approved it on February 8, 1935), certification by the U.S. President (certified March 23, 1935), and ratification by the Filipino people (May 14, 1935).
The Constitution was modeled largely on the U.S. Constitution, embodying ideals such as liberty, justice, democracy, separation of powers, and a bill of rights guaranteeing freedoms of speech, press, and religion.

Under Section 4 of the Tydings-McDuffie Act, the results of elections under the constitution were to be certified by the Philippine Governor-General to the U.S. President, who would then issue a proclamation inaugurating the new government.
The proclamation was issued on November 15, 1935, marking the official start of the Commonwealth government.

Section 2, Article XV of the Constitution provides that all existing Philippine laws shall remain in force until the Commonwealth's inauguration, and thereafter unless inconsistent with the constitution.

Whether sections 1439 and 2718 of the Revised Administrative Code, authorizing imprisonment for nonpayment of the cedula tax, are constitutional under the 1935 Philippine Constitution.
Whether the judgment convicting the appellant and sentencing him to imprisonment in accordance with section 2718 can stand after the Constitution’s effectivity.