FACTS: 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 provision
that punishes those who insults the Ministers of the Crown. Hence, the issue.
ISSUE: Whether or not Article 256 of the Spanish Penal Code (SPC) is still in force and
can be applied in the case at bar?
HELD: No.
REASONING: The Court stated that during the Spanish Government, Article 256 of the
SPC was enacted to protect Spanish officials as representatives of the King. However,
the Court explains that in the present case, we no longer have Kings nor its
representatives for the provision to protect. Also, with the change of sovereignty over
the Philippines from Spanish to American, it means that the invoked provision of the
SPC had been automatically abrogated. The Court determined Article 256 of the SPC to
be political in nature for it is about the relation of the State to its inhabitants, thus, the
Court emphasized that it is a general principle of the public law that on acquisition of
territory, the previous political relations of the ceded region are totally
abrogated. Hence, Article 256 of the SPC is considered no longer in force and cannot
be applied to the present case. Therefore, respondent was acquitted