G.R. No. L-9659; May 29, 1957
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALERIANO VALENSOY Y MASA, defendant-appellant.

FACTS

Valeriano Valensoy y Masa was charged in the Court of First Instance of Manila with violating section 26 of Act No. 1780 for concealing a bolo (a deadly weapon). He moved to quash the information, arguing that the title of Act No. 1780 , “An Act to regulate the importation, acquisition, possession, use, and transfer of firearms, and to prohibit the possession of same except in compliance with the provisions of this Act,” did not embrace weapons other than firearms. Therefore, the inclusion of section 26, which outlaws the concealment of deadly weapons like a bolo, violated the constitutional provision that “No bill which may be enacted into law shall embrace more than one subject which shall be expressed in the title of the bill.” The trial court denied the motion, reasoning that the constitutional prohibition at the time of Act No. 1780 ’s enactment (1907) referred only to private or local bills, and a law valid when enacted remains valid regardless of subsequent constitutional changes. At trial, the defendant admitted the facts but maintained his innocence based on the same grounds. The court found him guilty, sentenced him to pay a fine, and ordered him to pay costs. The defendant appealed.

ISSUE

Whether Act No. 1780 , specifically section 26, which prohibits the concealment of deadly weapons, became invalid or was repealed upon the effectivity of the 1935 Constitution because its title refers only to firearms, thereby violating the constitutional provision that no bill shall embrace more than one subject not expressed in its title.

RULING

The Supreme Court affirmed the judgment of the trial court. The Court held that the constitutional provision (Section 21[1], Article VI of the 1935 Constitution) requiring the subject of a bill to be expressed in its title applies prospectively to bills enacted after the Constitution took effect. Act No. 1780 was validly enacted in 1907 under the then-governing Organic Law (Act of Congress of July 1, 1902), which at that time limited the “one subject/title” requirement to private or local bills only. Pursuant to Section 2, Article XVI of the 1935 Constitution, all existing laws remained operative unless inconsistent with the Constitution. Since Act No. 1780 was not inconsistent with the new Constitution, section 26 thereof remained valid and operative. The constitutional provision cited by the appellant governs future legislative procedure and does not invalidate laws duly enacted prior to its effectivity.