G.R. No. 9726 - People vs. Taylor

The United States, as plaintiff and appellee, filed an action for criminal libel against Carson Taylor, defendant and appellant.
Carson Taylor was alleged to be the acting editor, proprietor, manager, printer, and publisher of the "Manila Daily Bulletin," a bilingual newspaper in English and Spanish with large circulation in the Philippines and abroad.
The complaint charged Taylor with willfully, unlawfully, feloniously, maliciously, and with intent to impeach the honesty, virtue, and reputation of Ramon Sotelo (a member of the bar and private individual), composing, printing, editing, publishing, and circulating a false and malicious libel against Sotelo in the issue dated September 25, 1913.

The article accused parties including Ramon Sotelo of conspiracy to defraud an insurance company by setting fire to a building at Calle O’Donnell to collect insurance proceeds.
It mentioned sworn statements by Vicente Sotelo and Eugenio Martin implicating attorney Ramon Sotelo among those involved in the conspiracy and fraud.
The article claimed the furniture was removed before the fire, the full amount of insurance was collected, and that criminal proceedings would be brought against the implicated parties including Sotelo.
Public understanding was that the article referred to Ramon Sotelo as the attorney who made an affidavit regarding the fire and who was subject to criminal charges.

Carson Taylor was arrested, arraigned, pleaded not guilty, tried before Judge George N. Hurd, found guilty of criminal libel, and sentenced to pay a P200 fine.
Taylor appealed the conviction, assigning errors including: liability as publisher, proprietor, or editor; whether the article was libelous per se; presence of malice; identification of the article with Ramon Sotelo; and Sotelo’s status as attorney for the plaintiff at the time of publication.

The prosecution presented the "Manila Daily Bulletin," showing it was owned by Bulletin Publishing Company, and that Taylor was the company manager.
There was no direct evidence proving that Taylor was the author, editor, or proprietor of the newspaper.
No proof was presented clarifying Taylor’s specific role or responsibility in the writing, editing, or publishing of the libelous article.

Whether Carson Taylor, as "manager" of the newspaper, could be held criminally liable under Act No. 277 as an author, editor, or proprietor of the newspaper for the alleged libel.
Whether the prosecution sufficiently proved Taylor’s status as author, editor, or proprietor as required by the libel law for criminal liability.
Whether Taylor’s conviction for criminal libel should be upheld given the evidence.