Case Summary (G.R. No. 43290)
Applicable Law and Legal Provisions
The prosecution was based on Section 1439 and Section 2718 of the Revised Administrative Code. Section 1439 identifies those liable to pay the cedula tax, while Section 2718 prescribes a misdemeanor for delinquency and authorizes the provincial treasurer to initiate prosecution for nonpayment, with a penalty of imprisonment for five days for each unpaid cedula. Importantly, Section 1, Clause 12, of Article III of the 1935 Philippine Constitution explicitly prohibits imprisonment for debt or for nonpayment of a poll tax.
Trial Proceedings and Appeal
Ambrosio Linsangan was convicted and sentenced to five days imprisonment and ordered to pay court costs for his nonpayment. He appealed the decision, challenging the constitutionality of the aforementioned provisions under the Revised Administrative Code, arguing that his imprisonment violated the prohibition against imprisonment for debt under existing laws and the newly promulgated Philippine Constitution.
Constitutional Context and Historical Background
At the time of the initial trial, the 1935 Philippine Constitution had not yet come into effect. However, while the appeal was pending, the new Constitution was ratified and became effective. This Constitution, promulgated under the authority of the Tydings-McDuffie Act of March 24, 1934—legislation passed by the United States Congress to provide the Philippines with Commonwealth status—contains a bill of rights, including the express prohibition against imprisonment for failure to pay a poll tax.
The Constitution was drafted by a constitutional convention beginning July 30, 1934, approved on February 8, 1935, certified by the U.S. President on March 23, 1935, ratified on May 14, 1935, and the Commonwealth government inaugurated on November 15, 1935.
Legal Effect of the 1935 Constitution on Existing Laws
Article XV, Section 2 of the 1935 Constitution provided for the continuation of all existing laws until the Commonwealth government was inaugurated. After inauguration, existing laws continued to operate unless inconsistent with the new Constitution.
The Court found that Section 2718 of the Revised Administrative Code, which permitted imprisonment for the nonpayment of the cedula tax, was inconsistent with the clear constitutional provision prohibiting imprisonment for nonpayment of a poll tax under Section 1, Clause 12, Article III of the 1935 Constitution.
Court’s Ruling and Legal Reasoning
The Supreme Court ruled that upon the inauguration of the Commonwealth government, the provisions of Section 2718 became inoperative due to direct conflict with the Constitution. Consequently, the imprisonment imposed o
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Facts of the Case
- Ambrosio Linsangan was prosecuted for nonpayment of the cedula or poll tax under Section 1439 in connection with Section 2718 of the Revised Administrative Code.
- After trial, the lower court sentenced Linsangan to five days imprisonment and ordered him to pay costs.
- Linsangan appealed, asserting that Sections 1439 and 2718 of the Revised Administrative Code were unconstitutional and void.
Legal Provisions Involved
- Section 1439 of the Revised Administrative Code specifies the persons obligated to pay the cedula tax.
- Section 2718 provides that if a person liable to pay the cedula remains delinquent for fifteen days after June 1 of each year and defies payment after demand by the provincial treasurer, such person commits a misdemeanor.
- Upon conviction, the delinquent shall be sentenced to imprisonment for five days for each unpaid cedula.
- The imposition of imprisonment is at the discretion of the provincial treasurer who may initiate prosecution before a justice of the peace.
Procedural History and Constitutional Context
- The case was tried before the Philippine Constitution became effective.
- While the appeal was pending, the new 1935 Philippine Constitution took effect.
- Section 1, Clause 12, of Article III of the Constitution states: “No person shall be imprisoned for debt or nonpayment of a poll tax.”
- The appellant argued that this constitutional provision rendered Sections 1439 and 2718 unconstitutional as they allowed imprisonment for nonpayment of the poll tax.
- Previous organic laws did not explicitly prohibit imprisonment for nonpayment of poll or cedula taxes, only for debt.
Historical and Political Context of the Constitution
- The 1935 Constitution was adopted under the Tydings-McDuffie Law (Act of Congress, March 24, 1934).
- The law authorized the Philippine