People v. Abad Santos
REITERATIONFacts
The Antecedents: The appellant, Antonio Abad Santos, owner of a printing establishment named "The Excelsior," was accused of violating Section 185 of Act No. 2339 (now section 2727 of the Administrative Code) for failing to make an entry in his business day book for January 5, 1915, as required by Circular No. 467 of the Collector of Internal Revenue. This circular mandated that printers and other businesses subject to specific taxes keep a day book detailing daily receipts and report any day with no business conducted. Procedural History: The appellant was convicted and sentenced to pay a fine of P10. The Petition: The appellant appealed the conviction.
Issue(s)
Whether the appellant can be held criminally liable for the omission of his bookkeeper in failing to make an entry in the business day book. Whether the statute and the circular, when read together, clearly impose criminal liability on the principal for the acts of his bookkeeper without the principal's knowledge or consent.
Ruling
The judgment of conviction is reversed, and the accused is acquitted.
Ratio Decidendi
On the issue of criminal liability for the acts of another: The Court held that the accused must be acquitted. It was undisputed that the appellant regularly employed a bookkeeper who was in complete charge of the business day book. The failure to make the required entry was due to the bookkeeper's omission, of which the appellant had no knowledge. The Court stated that a person should not be held criminally liable for the acts of another done without his knowledge or consent, unless the law clearly provides for such a consequence. The Government's contention that the principal is criminally responsible for the acts and omissions of his bookkeeper was not agreed upon by the Court. On the interpretation of the statute and circular: The Court found that neither the statute nor the circular, nor both combined, expressly required the imposition of criminal liability on the principal for the acts of his bookkeeper without the principal's knowledge or consent. The intention of the Legislature to impose such vicarious criminal liability was not so clear as to leave no room for doubt. The Court reiterated the principle that criminal statutes are to be strictly construed, and no person should be brought within their terms who is not clearly within them, nor should any act be pronounced criminal which is not clearly made so by the statute. The Court cited United States vs. Madrigal (27 Phil. Rep., 347) in support of this principle.
Main Doctrine
A person cannot be held criminally liable for the acts of another done without his knowledge or consent, unless the law clearly and unequivocally provides for such vicarious liability. Criminal statutes are to be strictly construed.