U.S. v.

GO CHICO

14 Phil 133

Facts: On or about the 4th day of August, 1908, appellant Go

Chico displayed in one of the windows and one of the show cases
of his store in No. 89 Calle Rosario, Manila, a number of
medallions, in the form of a small button, upon which were
printed the miniature faces of Emilio Aguinaldo and the flag or
banner or device used during the late insurrection in the Phil.
Islands to designate and identify those in armed insurrection
against the United States. On the day previous to the one set
forth above, the appellant had purchased the said medallion sold
at a public sale under the authority of the sheriff of the city of
Manila. On the day in question, the appellant was arranging his
stock of goods for the purpose of displaying them to the public,
and in doing so, he placed the medallions in his showcase and on
one of the windows of his store. The appellant was ignorant of any
law against the display of such medallions and had consequently
no corrupt intention. The facts stated above are admitted. The
appellant has two propositions for his acquittal: first is that before
a conviction can be had, a criminal intent upon the part of the
accused must be proved beyond a reasonable doubt. Second is
that the prohibition of law is directed against the use of identical
banners, devices or emblems actually used during the Philippine
insurrection by those in armed rebellion against the United States.

Issue: Whether or not criminal intent is necessary in crimes

punishable by special laws.
Held: The court ruled that the act alone, irrespective of its motive,
constitutes the crime. The words used during the late
insurrection in the Philippine Islands to designate or identify those
in armed rebellion against the United States mean not only the
identical flags actually used in the insurrection, but any flag which
is of that type. The description refers not to a particular flag, but
to a type of flag. The literal interpretation of a statute may lead to
an absurdity, or evidently fail to give the real intent of the
legislature.