People v. Go Chico
REITERATIONFacts
The Antecedents: The defendant, Go Chico, was charged with violating Section 1 of Act No. 1696 of the Philippine Commission. On or about August 4, 1908, in Manila, Go Chico displayed in his store a number of medallions imprinted with the picture of Emilio Aguinaldo and the flag or banner used during the Philippine insurrection. The appellant had purchased these goods, including the medallions, at a public sale the day before and was arranging his stock for display. He claimed ignorance of the law and no corrupt intention. Procedural History: The Court of First Instance of Manila found the defendant guilty and sentenced him to pay a fine of P500 and costs, with subsidiary imprisonment. The defendant appealed this judgment. The Petition: The appellant argued for acquittal on two grounds: (1) that criminal intent must be proven beyond a reasonable doubt for a conviction under the cited law, and (2) that the prohibition applies only to the identical banners used during the insurrection, not to duplicates.
Issue(s)
Whether criminal intent is a necessary element for a conviction under Act No. 1696. Whether the prohibition in Act No. 1696 extends only to the identical flags used during the insurrection or also to duplicates thereof.
Ruling
The judgment of the court below and the sentence imposed thereunder are affirmed.
Ratio Decidendi
On the necessity of criminal intent: The Court held that criminal intent is not a necessary element for a conviction under Act No. 1696. The Court reasoned that many statutory offenses are strict liability offenses where the intention of the person is immaterial. The pernicious effect sought to be avoided by the statute, which is the incitement to resistance to governmental functions and insurrection, is produced by the display itself, regardless of the actor's intent. Citing various authorities, the Court emphasized that the legislature may forbid an act and make its commission a crime without regard to the intent of the doer, especially when the act itself produces the evil the statute aims to prevent. The Court distinguished this from crimes where the injurious effect depends on the corrupt intention of the perpetrator, such as homicide, noting that in this case, the evil affects society through the public mind's reaction to the act itself, not the actor's state of mind. The Court concluded that the wording of the law is plain and means what it says, requiring only the commission of the prohibited act. On the scope of the prohibition: The Court rejected the argument that the law applies only to the identical banners used during the insurrection. The Court reasoned that it would be nonsensical to prohibit the display of the actual insurrectionary flags while permitting exact duplicates. Such an interpretation would nullify the statute. The phrase "used during the late insurrection..." was held to refer to a type of flag, not merely the specific physical flags used. This description was necessary because there was no other adequate way to identify that particular type of flag, its defining characteristic being its use in the insurrection. The Court emphasized that statutes should be construed to advance the remedy and suppress the mischief contemplated by the framers, and that the intention of the legislature, which was to prevent the display of symbols inciting rebellion, must control over a literal interpretation that would defeat the law's purpose.
Main Doctrine
Under Act No. 1696 of the Philippine Commission, the display of a flag, banner, emblem, or device used during the Philippine insurrection is prohibited, and criminal intent is not a necessary element for conviction; the act itself, regardless of the intent, constitutes the offense.