Title
People vs. Toribio
Case
G.R. No. 5060
Decision Date
Jan 26, 1910
Luis Toribio slaughtered a carabao in Carmen, Bohol without a permit, violating Act No. 1147; he argued the law applied only to slaughterhouses. Court ruled prohibition applies universally, upheld statute's police power, and affirmed conviction.
A

Case Digest (G.R. No. 5060)

Facts:

  • Background and Procedural History
    • The United States charged Luis Toribio with slaughtering a branded carabao for human consumption without securing a permit from the municipal treasurer of Carmen, Bohol, in violation of sections 30 and 33 of Act No. 1147.
    • At trial, evidence proved that Toribio caused the animal’s slaughter outside any municipal slaughterhouse; the town of Carmen had no such facility.
  • Statutory Framework (Act No. 1147, “An Act regulating the registration, branding, and slaughter of large cattle”)
    • Section 30 requires a permit from the municipal treasurer for slaughter of large cattle for food anywhere, and expressly for killing at a municipal slaughterhouse, conditioned on production of ownership certificates or other proof of title.
    • Section 31 limits permits to slaughter carabaos unfit for agricultural or draft use and forbids any permit for animals unfit for human consumption; Section 32 mandates detailed record-keeping of permits; Section 33 prescribes fines (₱10–₱500), imprisonment (1–6 months), or both for slaughter without permit.

Issues:

  • Statutory Construction
Does the phrase “at the municipal slaughterhouse” in sections 30 and 33 restrict the prohibition and penalty solely to slaughter occurring in such slaughterhouses, or do the provisions apply to the slaughter of large cattle for human consumption anywhere without permit?
  • Constitutional Validity
Is the requirement of a permit—and consequent penalty for slaughtering carabaos fit for agricultural work—an unconstitutional deprivation of property or a taking without compensation under section 5 of the Philippine Bill (due process clause)?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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