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Valensoy Case: Act No. 1780 Analysis

Valeriano Valensoy y Masa was charged with concealing a bolo in violation of Section 26 of Act No. 1780. Valensoy argued that the Act only regulated firearms and did not include other weapons. Additionally, he claimed the Act violated the constitutional requirement that a bill can only address one subject expressed in its title. The court held that the Act did not violate this requirement as it was already in force before the 1935 Constitution took effect, and existing laws remained operative unless inconsistent with the Constitution.

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Uriko Labrador
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122 views1 page

Valensoy Case: Act No. 1780 Analysis

Valeriano Valensoy y Masa was charged with concealing a bolo in violation of Section 26 of Act No. 1780. Valensoy argued that the Act only regulated firearms and did not include other weapons. Additionally, he claimed the Act violated the constitutional requirement that a bill can only address one subject expressed in its title. The court held that the Act did not violate this requirement as it was already in force before the 1935 Constitution took effect, and existing laws remained operative unless inconsistent with the Constitution.

Uploaded by

Uriko Labrador
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

People v.

Valensoy
Saturday, 27 July 2019 12:15 AM

FACTS:
- Valeriano Valensoy y Masa was charged in the Court of First Instance of
Manila with a violation of section 26, Act No. 1780 (concealment of a
bolo, about 9" blade with a leather sheath, a deadly weapon)
- Valensoy moved to quash the information on the following grounds;
(1) that as the title of Act. No. 1780, to wit: “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 include weapons other than firearms
(2) and that Section 26 violates the constitutional provision that “No bill
which may be enacted into law shall be expressed in the title of the bill.”

ISSUES: Whether or not Act No. 1780 violated the Constitutional provision
against enactment of bills into law embracing more than one subject not
expressed in the title of the bills.

HELD:
- No. Act No. 1780 was enacted on October 12, 1907, during this time, the
one subject-one title rule referred to bills to be enacted into a law, and
not to a law that was already in force and existing at the time the 1935
Constitution took effect.
- Section 26 remained operative at the time the Constitution took effect
because it was not inconsistent with the Constitution, pursuant to section
2, Article XVI of the 1935 Constitution, which reads: “All laws of the
Philippine Islands shall continue in force until the inauguration of the
Commonwealth of the Philippines; thereafter, such laws shall remain
operative...”

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