Case Summary (G.R. No. 4963)
Facts of the Case
Go Chico displayed medallions in his store's window and showcase, which bore the image of Emilio Aguinaldo and the flag or device associated with the Philippine insurrection. These medallions were part of the stock he purchased at a sheriff’s public sale the day before the display. The appellant admitted ignorance of any law prohibiting the display and claimed no corrupt intent. The Court of First Instance found him guilty and imposed a fine of five hundred pesos and costs, with subsidiary imprisonment as prescribed.
Issue on Criminal Intent – Strict Liability Crime
The defendant argued that conviction required proof of criminal intent beyond reasonable doubt. The Supreme Court held that criminal intent was unnecessary for conviction under this statute. The Court emphasized that some statutory offenses, especially those enacted to protect public order, are mala prohibita, where the wrongful act itself constitutes the crime irrespective of intent. The display of flags or devices associated with rebellion inherently threatens governmental authority and public order, making the act itself punishable without regard to the actor’s awareness or motive.
Judicial Precedents on Intent in Statutory Offenses
The Court cited numerous precedents illustrating the principle that public welfare and regulatory offenses may dispense with mens rea (criminal intent). Cases involving adulterated milk, public official removals, illegal disbursement of public funds, and statutory transpositions of materials upheld that knowledge or fraudulent intent is not an element of the offense. The purpose is deterrence and enforcement, ensuring public safety and government authority, which cannot depend on proving subjective intent. This principle applied similarly in the present case.
Distinction Between Intent to Commit the Crime and Intent to Commit the Act
The decision draws a clear distinction between the intention to perform a prohibited act and the intention to violate the law. Although the defendant did not intend to commit a crime, he intended to place the medallions on display, an act that the statute criminalizes regardless of intent. The Court underscored that the statute’s wording links the act and the crime inseparably, rendering intent to commit the crime immaterial.
Interpretation of the Type of Banner or Emblem Prohibited
The defendant also contended that the law applied only to the specific flags used during the insurrection, not to duplicates. The Court rejected this, holding that the statute targeted the type or class of flags associated with the insurrection, not solely the original physical flags. The phrase “used during the late insurrection” served as a descriptive device to identify the type of flag intended, not limiting prohibition to exact originals. To construe otherwise would render the statute meaningless.
Principles of Statutory Construction Applied
The Court applied fundamental rules of statutory interpretation: penal statutes must be construed strictly to protect defen
...continue readingCase Syllabus (G.R. No. 4963)
Case Background and Statutory Provision
- The defendant Go Chico was charged with violating Section 1 of Act No. 1696 enacted by the Philippine Commission.
- The statute prohibits any person from exposing or permitting to be exposed to public view on their own or other premises any flag, banner, emblem, or device:
- Used during the Philippine insurrection to identify armed rebels against the United States.
- Used or adopted at any time by enemies of the United States in the Philippines for public disorder, rebellion, or insurrection against U.S. authorities.
- Of the Katipunan Society or commonly known as such.
- Violation of this statute is punishable by a fine ranging from 500 to 5,000 Philippine pesos, imprisonment from three months up to five years, or both, at the court’s discretion.
Facts of the Case
- On August 4, 1908, in Manila, Go Chico displayed medallions as small buttons in his store's window and showcase bearing the picture of Emilio Aguinaldo and the flag or device used during the Philippine insurrection.
- The medallions were part of the stock of goods Go Chico acquired the day before at a sheriff’s public sale.
- When displayed, Go Chico was arranging his stock to present goods to the public.
- The defendant admitted ignorance of the law prohibiting such display and did not harbor any corrupt or criminal intent.
- Based on these facts, Go Chico was convicted by the Court of First Instance, fined 500 pesos plus costs, and sentenced to subsidiary imprisonment pending payment.
- He appealed this conviction to the Supreme Court.
Legal Issues Raised by the Defendant
- Go Chico presented two main defenses:
- A criminal intent must be proven beyond reasonable doubt before a conviction under the statute.
- The statute applies only to the display of the exact, original flags or emblems used during the insurrection, not to duplicates or replicas.
Supreme Court’s Holding on Criminal Intent
- The Court ruled that criminal intent is not a necessary element for conviction under this statute.
- It highlighted the nature of statutory crimes where the act itself constitutes the offense irrespective of intent.
- The statute is designed as a deterrent, rendering proof of corrupt intention unnecessary and impractical.
- Rationalized that the display of a rebel flag induces insurrection and public disorder no matter the exhibitor’s intent or knowledge.
- Distinguished this from common law crimes requiring mala in se (wrong-in-itself) where intent is essential (e.g., murder).
- Cited numerous authorities supporting the