G.R. No. 1914
August 12, 1905

FACTS:
Chin Tze was convicted in the Court of Customs Appeals for violating the immigration laws. The conviction was based on Section 11 of the Act of Congress of May 6, 1882, as amended by the Act of July 5, 1884. These provisions were continued in force by subsequent acts of Congress, including the Act of May 5, 1892 (which extended them for ten years) and the Act of April 29, 1902 (which made them applicable to the Philippine Islands). The defense argued that the Act of July 5, 1884, had been abrogated by Section 15 of the Act of Congress of September 13, 1888.

ISSUE:
Whether the Act of July 5, 1884specifically Section 11 of the Act of May 6, 1882, as amendedremained in force at the time of Chin Tze’s offense, thereby validating his conviction.

RULING:
The Supreme Court affirmed the conviction. It held that the Act of July 5, 1884, was not abrogated. Section 15 of the Act of September 13, 1888, provided that abrogation would only take effect upon the ratification of a specific treaty with China, which was never ratified. Thus, the abrogation never occurred. The Court further noted that the provisions were extended by the Act of May 5, 1892, and later made applicable to the Philippine Islands by the Act of April 29, 1902, remaining in force at the time of the offense. The evidence supported the trial court’s findings, and no prejudicial error was found in the proceedings. The sentence was affirmed with costs against the appellant.