Title
People vs Go Chico
Case
G.R. No. 4963
Decision Date
Sep 15, 1909
Go Chico displayed medallions depicting Emilio Aguinaldo and a rebel flag, violating Act No. 1696. Court ruled intent irrelevant; displaying prohibited symbols, even unknowingly, constitutes the offense.

Case Digest (G.R. No. 4963)
Expanded Legal Reasoning Model

Facts:

  • Nature of the Case
    • The defendant, Go Chico, was charged with violating section 1 of Act No. 1696 of the Philippine Commission.
    • The said Act penalizes any person who exposes to public view on his own or elsewhere premises any flag, banner, emblem, or device used during the late insurrection in the Philippines to identify rebels against the United States or any flag adopted by public enemies for purposes of rebellion, including the flag of the Katipunan Society.
    • The penalties prescribed were a fine between five hundred to five thousand pesos, imprisonment from three months to five years, or both.
  • Details of the Offense
    • On or about August 4, 1908, in Manila, Go Chico displayed medallions (small buttons) in his store windows bearing miniature pictures of Emilio Aguinaldo and the flags or emblems used during the Philippine insurrection.
    • Go Chico had acquired the stock, including the medallions, the day before through a public sheriff’s sale of the store’s goods.
    • He was in the process of arranging his merchandise for public display and placed the medallions in his store's window and showcase.
  • Defendant’s Position
    • Go Chico claimed ignorance of the law prohibiting the display of such emblems and asserted no corrupt intent in displaying them.
    • He sought acquittal based on two main propositions:
      • A criminal intent must be proven beyond reasonable doubt before conviction.
      • The law only prohibits displaying the identical flags and devices actually used during the insurrection, not duplicates or replicas.
  • Trial and Appeals
    • The Court of First Instance of Manila found Go Chico guilty on September 8, 1908, and imposed a fine of P500 and costs, with subsidiary imprisonment until payment.
    • The defendant appealed to the Supreme Court of the Philippines.

Issues:

  • Whether criminal intent is an essential element that must be proven beyond reasonable doubt in the violation of Section 1 of Act No. 1696.
  • Whether the statute applies only to the display of the exact, original flags used during the late insurrection or also to replicas and duplicates of those flags, banners, or emblems.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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