THE GREEN BAG instrument. In his experience their admin istration of it was honest and efficient. JURISPRUDENCE (Philippines). Charles S. Lobingier, one of our judges in the Philip pines, describes in the October Law Quarterly Review (V. xxi, p. 401) " Blending Legal Sys tems in the Philippines." After briefly ex plaining the changes we have so far made in the Spanish codes, he calls attention to the fact that " besides the Roman and the Eng lish the world has produced but a single other legal system which has grown to the propor tions of a cosmopolitan one. This is the Mo hammedan law whose principles determine the rights and duties of the almost countless hosts of Islam from its westernmost outpost in Morocco to its eastermost in Mindanao. No other system save these three has become the law of more than one nation or sover eignty, and it is not a little curious that all of these cosmopolitan systems are now found side by side in the Philippines alone." From this blending of systems he believes that an opportunity will arise for some future codifier in the Philippines to develop a system which will surpass that of all his predecessors. "Such, then, is the new jurisprudence forming in the Philippines through the blend ing of diverse legal systems — the Spanish, preserving and continuing the law of old Rome with the garnered wisdom of its mighty jurisconsults — the American, inheriting and contributing the great principles of the English common law, won by the struggles of sturdy yeomen, formulated by a long line of illustrious judges, and tempered with the practical common sense of the Anglo-Saxon; and with it all perhaps a strain from those crude systems which antedate all others in the archipelago. It is a unique process — this blending of legal systems in the Philippines, and, except possibly in the early days of Louisiana, history furnishes no parallel. And as Sir Henry Maine found in the Livingston Code — an outgrowth of the peculiar condi tions in Louisiana — the best example of codification, some future codifier in the Philip pines may find the materials which will enable him to surpass all predecessors. "The results of this process are already per ceptible not only in the laws themselves but
in the attitude of those who interpret and apply them. The American judge or lawyer who comes to the Philippines finds that he has much to receive as well as to give — that while his colleagues among the Filipinos may not have had the advantage of an early training in the remedial part of their present law, they are more familiar than he with the substantive element, and that each can learn something from the other. This conduces to a spirit of mutual helpfulness and to mutual concessions, which make the work of adminis tering the law far easier and more agreeable. The American and Filipino Bar Associations, formerly distinct, are now one, and the united body recently tendered a banquet to Chiefjustice Arellano (a Filipino), upon his return from a visit to the United States, at which the toast-master was an American and the speakers both Americans and Filipinos. A distinguished member of the Manila bar, enter taining at dinner recently some lawyer friends of both races, remarked that nowhere else in the world could such fraternizing be found. May it indeed prove the augury of harmonious relations in all walks of life between the two races whom destiny seems to have assured a common future." JURISPRUDENCE (see History). NEGOTIABLE INSTRUMENTS (see Sales). PATENTS. In the November Harvard Law Review (V. xix, p. 30), William B. Whitney under the title of " Patentable Processes" contends that recent decisions of the Supreme Court have confused an important portion of patent law. A patent may be granted for a "useful art." A process (a series of acts pro ducing physical change) is such an art, but the court has inserted a qualification " pro vided it involves a chemical or other elemental change." A process that does not invoke any power of nature to effect a result that may be produced by simple manipulation, though ordi narily and most successfully performed by machinery ought to be patentable. To hold the contrary would nullify the act and over rule decided cases. But a doubt is raised by recent cases. A further proposition of the court that a
