Title
People vs Look Chaw
Case
G.R. No. 5889
Decision Date
Jul 12, 1911
Look Chaw, convicted for unauthorized opium sale in Cebu, argued isolated sale, not business. Court ruled confessions valid, rejected double jeopardy, reduced penalty.

Case Summary (G.R. No. 5889)

Facts of the Case

On August 18, 1909, Look Chaw was accused of engaging in the business of selling opium without the necessary authorization from the Collector of Internal Revenue. Internal-revenue agent C. J. Milliron testified about Vicente Base's actions in bringing opium to the governor of Cebu, allegedly sold by the accused. Look Chaw confessed to selling thirty cans of opium to Base but claimed no monetary gain from this sale, stating that the money discovered on-board the British steamship Erroll was seized from him and that he intended to introduce the opium contraband into Mexico.

Charges and Trial Proceedings

The charges against Look Chaw included selling opium without legal authorization, as delineated in the pertinent sections of Act No. 1761. The trial court convicted him, sentencing him to a year of imprisonment and a fine of P2,000, pending additional subsidiary imprisonment in the event of insolvency. The court also ruled for the confiscation of exhibits related to the case and mandated Look Chaw’s transfer to customs authorities post-sentence to enforce immigration laws.

Appeal Arguments

Look Chaw contested his conviction on the grounds that his actions did not constitute engaging in the business of selling opium, arguing that an isolated sale does not equate to conducting business. He invoked section 15 of the Act, which emphasizes the necessity of obtaining prior authorization for such transactions. The defense delineated between single transactions (isolated sales) and continuous operations (engagement in selling as a business).

Court Findings on Charges

The appellate court addressed the distinction between selling and possessing opium as outlined in separate sections of the relevant act. It clarified that the sale of opium without authorization constituted a criminal act and rejected the appellant's interpretation of his actions as mere isolated sales. The court deemed the evidence provided, including the confession, sufficient to uphold the lower court's decision.

Double Jeopardy Defense

An additional argument raised by the defense concerned claims of double jeopardy. Look Chaw contended that he should not be tried twice for linked offenses—possession and sale of opium. The court found that the defendant's counsel had effectively induced the court to separate complaints regarding possession and sale, thus nullifying the double jeopardy claim. The court reasoned that possession could exist independently of the sale, and as such, the defendant's convictions for both crimes were warranted.

Judicial D

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