People vs Perfecto Case Digest – Gr No L-18463, October 4, 1922

People vs Perfecto Case Digest

People vs Perfecto Case Digest


The issue started when the secretary of the Philippine Senate, Fernando Guerrero, discovered that the documents regarding the testimony of the witnesses in an investigation of oil companies had disappeared from his office.

Then the day following the convening of Senate, the newspaper La Nacion – edited by herein respondent Gregorio Perfecto – published an article against the Philippine Senate. Here, Mr. Perfecto was alleged to have violated Article 256 of the Spanish Penal Code.

Laurel vs Misa Case Digest – GR No. L-409, January 30, 1947


Whether Article 256 of the Spanish Penal Code is still in force and can be applied in the case at bar.


The change of sovereignty over the Philippines from Spanish to American means that the involved provision of the SPC had been automatically abrogated. The Court determined it to be political in nature.

Article 256 of the SPC is considered no longer in force and can not be applied to the present case. Therefore, the respondent was acquitted.

People vs Perfecto Case Digest

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