1. People of the Philippines vs. Gregorio Perfecto (G.R. No.

L-18463)
Alfonso E. Mendoza and the appellant in behalf of the latter.
Attorney-General Villa-Real for appellee
Facts:
Mr. Gregorio Perfecto, editor of newspaper La Nacion, published an article which implied the
Philippine Senate of corruption. This is because the documents which constitutes testimonials of
the witnesses regarding the investigation of oil companies were lost. An assistant city fiscal has
filed an information to the municipal cour. The municipal court and the Court of First Instance in
Manila has found Mr. Gregorio Perfecto guilty in violation of Article 256 of the Spanish Penal
Code. The trial judge dictates that Perfecto is guilty using a similar case of oral defamation
against the President of the United States (United States vs Helbig). Article 256 states that
defamation, abuse, and insult of a Minister of the Crown or any other person in authority shall
suffer the penalty of arresto mayor.
Issue:
Whether or not Article 256 of the Spanish Penal Code, is still relevant and enforceable in the
Philippines.
Ruling:
The supreme court has decided to reverse the decision of the lower court and acquit Perfecto of
the charges. First, the change from Spanish to American sovereignty removes any Ministers of
the Crown and their representatives from the government, thus rendering the provision obsolete.
Furthermore, Article 256, which is inconsistent with democratic principles was abrogated
completely, upon the change from Spanish to American sovereignty. Second, The Philippine
Libel Law, Act No. 277, has repealed Article 256. Section 13 of the Philippine Libel Law
provides that "All laws and parts of laws now in force, so far as the same may be in conflict
herewith, are hereby repealed. . ..” Therefore, the provision is no longer applicable in the
Philippines.