Case Digest (G.R. No. 8646)
Facts:
The United States v. Benito Siy Cong Bieng and Co Kong, G.R. No. 8646, March 31, 1915, the Supreme Court En Banc, Carson, J., writing for the Court. The plaintiff-appellee was the United States; the defendants below were Benito Siy Cong Bieng (owner of a tienda) and Co Kong (his agent and employee). Benito alone appealed from conviction.
At the trial court (the "court below") both defendants were convicted under Section 7 of Act No. 1655 (the Philippine Pure Food and Drugs Act) for the sale of adulterated and falsely branded coffee and were each fined P10 and one-half of the costs. Only Benito appealed to the Supreme Court. The parties stipulated and the stipulation was read into the record: Benito was owner of tienda No. 326, Calle Santo Cristo; Co Kong was his duly installed agent and employee; on July 2, 1912 Co Kong, in the ordinary course of business, sold coffee that was adulterated and falsely branded; Benito had no knowledge that Co Kong would sell that coffee or any special brand of adulterated coffee and it was not manufactured or put up with Benito's knowledge.
The appeal presented two questions: (1) whether conviction under the Pure Food and Drugs Act can be sustained where the sale was made without the seller's guilty knowledge or conscious intent to violate the statute, and (2) whether a principal may be criminally convicted for the sale of adulterated goods by his agent acting in the regular course of employment when the principal lacked knowledge of the adulteration. The Supreme Court considered precedent and doctrinal auth...(Subscriber-Only)
Issues:
- Under Act No. 1655, may a conviction for selling adulterated food products be sustained absent proof that the seller had guilty knowledge or criminal intent?
- Can a principal (owner of a tienda) be held criminally responsible under Act No. 1655 for an adulterated sale made by his agent or employee in the regular course of business when the principal lac...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)