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each case. He had the bonds prepared, signed by himself and sureties, and came be fore a notary, where they were duly acknowl edged and certified to by the notary. Filing his bonds, he collected all the taxes he could conveniently gather and sailed for Spain, but afterwards changed his destination to Paris, in "order to enjoy more readily the fruits of his enterprise. In the meantime it was dis covered that the persons who acknowledged and signed the bonds were not the persons who they represented themselves to be; in other words, that the documents were for geries. Extradition proceedings were set in motion, and the absconding tax collector brought back. He was put upon his trial for emitting forged instruments, and the notary for making false certificates. Each was con victed, the tax collector being sentenced to twenty-four years' imprisonment, and the no tary to six months. The cases were brought to the Supreme Court in regular course on ap peal. That of the tax collector was affirmed. The notary's case presented some peculiari ties. The Spanish code makes a very marked difference between a public and a private in strument, and the punishment is different when a false certificate is made with or with out malice. Strange as it may appear, these official bonds, under the code, are private in struments, from the fact that they were not executed with the formalities required for public instruments. If they had been pub lic instruments and the notary had certified to them, malice would not be necessary to be proven, but would be presumed. Being private instruments, it was necessary to prove malice in making the certificate. However, the District Court found the instruments to be private instruments, which was a correct finding, and they also found that the notary had acted without malice. Nevertheless, they sentenced him to six months' imprison ment. This was held to be erroneous, be

cause the instrument being a private one, as found by the trial court, and the malice not being proven, it was impossible to convict of reckless negligence, which had been the charge, and on which judgment he was sen tenced. The case was reversed, and the notary exonerated. The defendant being a very well-known and popular man, of influen tial connections, the case made quite a noise from Fajardo to Mayaguez. One of the most important civil cases which has been tried before the Supreme Court was a divorce case, involving the con struction of the Organic Act, which provides that " All persons lawfully married in Porto Rico shall have all the rights and remedies conferred by law upon parties to either civil or religious marriages." The District Court held that this language meant that the mar riages to which it referred must have been performed in the Island of Porto Rico, and, as the parties litigant were married in Spain, that the Organic Act did not apply to their case, and further, that being citizens of Spain they were governed in their marital relations by the laws of Spain, and not by the laws of the United States. As no divorce can be granted under the Spanish law, the divorce was refused. The decision of the District Court in both of these particulars was re versed by the Supreme Court, and the divorce granted. There are cases pending in the Supreme Court at present, involving the question as to whether conspiracies to raise the price of labor are punishable in Porto Rico, as they were under the Spanish code, and whether or not newspapers prior to publication have to comply with all the restrictions imposed by the Spanish codes, and in several other cases of apparent conflict between the exist ing code and the Constitution and laws of the United States. The late decisions made by the Supreme Court of the United States