People vs. Perfecto 43 Phil 887 FACTS: The Secretary of the Philippine Senate, Fernando M.

Guerrero, discovered that certaindocuments, which constituted the records of testimony given by witne sses in the investigation of oilcompanies, had disappeared from his office. The day following the convening of the Senate, thenewspaper La Nacion, edited by Mr. Gregorio Perfecto, published an article regarding what happened.Perfecto was pr osecuted for writing an editorial against the Philippine Senate. The editorial i n questionwas alleged to have violated Art. 256 of the Penal Code, punishing ins ults to Ministers of the Crown. ISSUE: Whether Article 256 of the Spanish Penal Code is still in force. RULING: The Supreme Court acquitted him, holding that the particular article, of the said Code had beenautomatically abrogated, being political in nature, upon the advent of American sovereignty.Furthermore, Article 256 of the Penal Code is contrary to the genius and fundamental principles of theAmerican character and system of government. The gulf which separates this article from this spiritwhic h inspires all penal legislation of American origin, is as wide as that which se parates a monarchyfrom a democratic republic like that of the Unite States. Puni shment for contempt of non-judicialofficers has no place in a government based u pon American principles. The American system of government is calculated to enfo rce respect and obedience where such respect and obedience is due,but never does it place around the individual who happens to occupy an official position by ma ndate of the people any official halo, which calls for drastic punishment for co ntemptuous remarks.In the case of People vs. Perfecto ([1922], 43 Phil., 887), t he accused was charged with having publishedan article reflecting on the Philipp ine Senate and its members in violation of article 256 of the PenalCode. In this court, Mr. Perfecto was acquitted by unanimous vote, with three members of the courtholding that article 256 was abrogated completely by the change from Spanis h to American sovereigntyover the Philippines, and with six members holding that the Libel Law had the effect of repealing somuch of article 256 as relates to w ritten defamation, abuse, or insult, and that under the informationand the facts , the defendant was neither guilty of a violation of article 256 of the Penal Co de nor of the libel Law.