G.R. No. 6395, September 8, 1911
THE UNITED STATES, plaintiff-appellant, vs. VALENTIN FONSECA and JOAQUIN MAGNO, defendants-appellees.

FACTS

On June 18, 1910, the prosecuting attorney of Cebu filed a complaint in the Court of First Instance against Valentin Fonseca and Joaquin Magno for the crime of perjury. The complaint alleged that during the trial of a civil case in May 1910, the defendants, under oath, willfully testified to facts they did not believe to be true. The complaint was based on Section 3 of Act No. 1697 of the Philippine Commission. The defendants filed a demurrer, arguing that the complaint was not drawn in accordance with law and that the facts alleged did not constitute a crime. The trial court, through Judge Adolph Wislizenus, sustained the demurrer. The court held that Section 3 of Act No. 1697 was invalid because its provisions on perjury (which applied to false testimony before any tribunal) were broader than what was expressed in the Act’s title (“An Act authorizing the appointment of commissioners to make official investigations… and for the punishment of perjury in official investigations”). The court found this inconsistency violated Act No. 6 of the Commission. The prosecuting attorney refused to amend the complaint to base it on the Penal Code, preferring a definitive ruling on the validity of Act No. 1697. The court then ordered the accused released. The government appealed.

ISSUE

Whether Section 3 of Act No. 1697, which defines and punishes the crime of perjury, is valid despite its title being arguably narrower than its substantive provisions.

RULING

The Supreme Court REVERSED the trial court’s decision and REMANDED the case for further proceedings. The Court held that Section 3 of Act No. 1697 is valid and has repealed the pertinent articles on perjury in the Penal Code.

The Court ruled that the provision in Section 1 of Act No. 6 (requiring the title of an act to state its purpose and scope) is merely a rule for the legislature’s guidance and is not mandatory. The only mandatory constitutional requirement regarding titles is found in Section 5 of the Philippine Bill of 1902 (Act of Congress of July 1, 1902), which states: “That no private or local bill which may be enacted into a law shall embrace more than one subject, and that subject shall be expressed in the title of the bill.” This requirement applies only to private or local bills, not to general laws like Act No. 1697. Therefore, the legislature was not bound to strictly confine the act’s contents to its title. The Court cited its prior decisions in U.S. vs. Concepcion, U.S. vs. De Chaves, and U.S. vs. Estraña, which had already upheld the validity of Section 3 of Act No. 1697 and held that it repealed the Penal Code provisions on perjury. Consequently, the complaint based on Act No. 1697 was valid, and the demurrer should have been overruled.