Case Digest (G.R. No. 215955)
Facts:
The case of The United States vs. Juan Pons (G.R. No. 11530, August 12, 1916) involves the illegal importation of opium into the Philippine Islands during the American colonial period. On or about April 10, 1915, Juan Pons, Gabino Beliso, and Jacinto Lasarte were charged with conspiring to unlawfully import and introduce 125 kilograms of opium contained in 520 tins, valued at P62,400, aboard the Spanish mail steamer Lopez y Lopez, which arrived in Manila from Spain. The opium was disguised as barrels of wine consigned to Lasarte but was in fact smuggled prohibited substances. Pons, alleged to be directly involved, was separately tried and convicted by the lower court at Manila. He was sentenced to two years imprisonment at Bilibid Prison, fined P1,000 plus subsidiary imprisonment in case of insolvency, and ordered to pay half of the costs. Beliso was also convicted, with a higher fine of P3,000, but later withdrew his appeal, making his conviction final. Pons appealed on multip
Case Digest (G.R. No. 215955)
Facts:
- Parties and Charges
- The United States, plaintiff and appellee, charged Gabino Beliso, Juan Pons, and Jacinto Lasarte with illegal importation of opium.
- The information alleged that on or about April 10, 1915, the accused conspired to import 520 tins containing 125 kilograms of opium into Manila aboard the steamer Lopez y Lopez from Spain, concealing and receiving the opium unlawfully.
- Trial and Sentence
- Juan Pons and Gabino Beliso were tried separately; Jacinto Lasarte was not yet arrested at the time.
- Both Pons and Beliso were found guilty; Pons was sentenced to two years’ imprisonment, fined P 1,000, and ordered to pay one-half of costs, while Beliso was fined P 3,000 with similar penalties.
- Beliso withdrew his appeal, rendering his conviction final.
- Appellant’s Contentions
- Juan Pons moved to question the validity of Act No. 2381 under which he was punished, alleging it was approved March 1, 1914, after the special session of the Philippine Legislature ended February 28, 1914, and thus null and void.
- The key issue was whether the Legislature adjourned on February 28 or March 1, and whether the court could take judicial notice of legislative journals as conclusive evidence of the adjournment date.
- Evidence of Adjournment
- The journals of the Philippine Commission showed on page 793, volume 7, that the Legislature adjourned sine die at midnight on February 28, 1914.
- The Philippine Assembly journals similarly stated adjournment sine die at 12 midnight on February 28, 1914.
- Provisions of the Code of Civil Procedure and related laws mandated that official acts and journals of the legislative bodies be judicially recognized without the need for proof, or proven by certified copies.
- Investigation and Discovery of Smuggling
- On or about April 5–6, 1915, the steamer Lopez y Lopez arrived from Spain bringing 25 barrels manifested as “wine” consigned to Jacinto Lasarte, with delivery documents handled by Beliso to a customs broker.
- The barrels were delivered to Beliso’s warehouse; customs authorities, suspecting the shipment, began investigation and traced the barrels through registry and entry numbers.
- On April 9, five barrels were selected and delivered by an employee to Juan Pons at a house on Calle General Solano.
- The customs agents, with assistance from Pons’ employee, located 20 barrels at the warehouse and five barrels (empty) at the Calle General Solano address, where they found 77 tins of opium hidden in lime baskets.
- Investigators determined the house was rented by a fictitious “F. C. Garcia,” whose lease was signed by Juan Pons.
- Opening three barrels from warehouse, agents found large tins containing 195 small tins of opium identical to those found at the rented house.
- Pons was arrested, voluntarily confessed knowledge and participation in the smuggling, admitted prior partnership with Beliso, had shared profits, and explained how opium was concealed and distributed.
- Further search at Pons’ own premises revealed similar tins of opium; Pons gave inconsistent statements regarding “F. C. Garcia,” eventually admitting Garcia was fictitious and that the house was leased on Garcia’s letter, which he destroyed fearing self-incrimination.
- Trial Court Findings
- The court concluded that Pons actively participated in the smuggling operation, profited from it, knowingly received, concealed, and handled the illegal opium importation.
- The court found the legislative journals conclusive as to the date of adjournment February 28, 1914.
- The penalty imposed was in accord with existing laws and precedents.
Issues:
- Whether the court erred in denying appellant Juan Pons’ motion challenging the validity of Act No. 2381 on the ground that it was passed after the Legislature’s adjournment and thus void.
- Whether the court erred in ruling that the legislative journals are conclusive evidence of the date of adjournment of the Philippine Legislature’s special session of 1914.
- Whether the evidence established the guilt of Juan Pons beyond a reasonable doubt in the illegal importation of opium.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)