US v Pons

Facts:

Gabino Beliso, Juan Pons and Jacinto Lacarte were charged with the crime of illegal importation of Opium.

Juan Pons and Gabino Beliso were tried separately. Both were found guilty and both appealed but Beliso later withdrew his appeal.

Pons questioned the validity of Act. 2381 and offered to prove that the last day of the special session of the Philippine Legislature for
1914 was the 28th day of February; that Act No. 2381, under which Pons must be punished if found guilty, was not passed or approved
on the 28th of February but on March 1 of that year; and that, therefore, the same is null and void.

Issues:

1. W/N the court can look to legislative journals as proof of when the adjournment of Legislature happened
2. W/N the court can go behind the legislative journals to determine the date of adjournment

Ruling:

Yes. Section 275 of the Code of Civil Procedure provides that the existence of the "official acts of the legislative, executive, and judicial
departments of the United States and of the Philippine Islands ... shall be judicially recognized by the court without the introduction of
proof..”

While there are no adjudicated cases in this jurisdiction upon the exact question whether the courts may take judicial notice of the
legislative journals, it is well-settled in the US that such journals may be noticed by the courts in determining the question whether a
particular bill became a law or not.

The result is that the law and the adjudicated cases make it the Court’s duty to take judicial notice of the legislative journals of the
special session of the PH legislature of 1914.

These journals are not ambiguous or contradictory as to the actual time of the adjournment. They show, with absolute certainty, that
the Legislature adjourned sine die at 12:00 mn on 2/28/1914.

The court did not go behind the legislative journals when such journals are already clear and explicit (about when Act No. 2381 was
adjourned). “…to inquiry into the veracity (accuracy) of the journals of the Philippine Legislature, when they are, as we have said,
clear and explicit, would be to … interfere with the legitimate powers and functions of the Legislature.” The journals already say that
the Legislature adjourned at 12 midnight on February 28, 1914.