THE UNITED STATES, plaintiff-appellee, vs.

CARSON TAYLOR, although libel is made a crime, the defendant is not the author, editor,
defendant-appellant. or proprietor of the said newspaper—instead, only its manager.
Neither does the proof show in the record that the manager played a
G.R. No. L-9726 December 8, 1914
part in the publication of the article.

Nature of the Action: An appeal for criminal libel

Facts: Defendant, as alleged, was then and there the acting editor and
proprietor, manager, printer, and publisher of Manila Daily Bulletin, a
paper of large circulation edited in English and Spanish. Thereafter, an
article against one Atty. Ramon Sotelo was published in said newspaper
which implicated that there had been conspiracy and fraud between
said attorney and owner of the burnt building so as to collect insurance.
Atty. Sotelo further contended that the article was of a certain false and
malicious defamation and libel. The CFI agreed to Atty. Sotelo; hence,
this appeal.

Issue: Did the lower court erred in ruling that the defendant was
criminally liable?

Ruling: For the foregoing reasons, therefore, there being no proof

whatever in the record showing that the defendant was the “author, the
editor, or the proprietor” of the newspaper in question, the sentence of
the lower court must be reversed, the complaint dismissed and the
defendant discharged from the custody of the law, with costs de officio.

Ratio Decidendi: Yes; explained by the Supreme Court, common law

crimes do not exist in the Philippine islands. Thus, an act does not
constitute a crime when no law makes it so. In the instant case,
People vs. Siton, et al. Ruling:
GR 169364, 18 Sept. 2009 No. Article 202 (2) of the RPC does not violate the equal protection
clause; neither does it discriminate against the poor and the
unemployed.
Facts:
Offenders of public order laws are punished not for their status, as for
Respondents Evangeline Siton and Krystel Kate Sagarano were charged being poor or unemployed, but for conducting themselves under such
with vagrancy pursuant to Art. 202 (2) of the RPC in two separate circumstances as to endanger the public peace or cause alarm and
Informations. Accused were found wandering and loitering around San apprehension in the community.
Pedro and Legaspi Streets of Davao City, without any visible means to
Being poor or unemployed is not a license or a justification to act
support herself nor lawful and justifiable purpose.
indecently or to engage in immoral conduct.
Respondents filed separate Motions to Quash on the ground that Art.
202(2) is unconstitutional for being vague and overbroad. The
municipal trial court denied the motions, directed respondents to file
their respective counter-affidavits, and declared that the law on
vagrancy was enacted pursuant to the State’s police power (or the
power of promoting public welfare by restraining and regulating the
use of liberty and property) and justified by the Latin maxim “salus
populi est suprema lex” (which calls for the subordination of individual
benefit to the interest of the greater number).
Respondents filed a petition for certiorari and prohibition with the RTC
challenging the constitutionality of the anti-vagrancy law and claiming
that Art 202 (2) violated the equal protection clause. The RTC granted
the petition of the herein respondents and declared Art. 202 (2)
unconstitutional.

Issue:
Does Article 202 (2), RPC on vagrancy violate the equal protection
clause?
DOMINADOR B. BUSTOS vs. ANTONIO G. LUCERO HELD:
G.R. No. L-2068, Evidence is the mode and manner of proving competent facts and
circumstances on which a party relies to establish the fact in dispute in
October 20, 1948
judicial proceedings. It is fundamentally a procedural law. The Supreme
Court that section 11 of Rule 108 does not curtail the sound discretion
of the justice of the peace on the matter. Said section defines the
FACTS:
bounds of the defendant's right in the preliminary investigation, there
The petitioner herein, an accused in a criminal case, filed a motion with is nothing in it or any other law restricting the authority, inherent in a
the Court of First Instance of Pampanga after he had been bound over court of justice, to pursue a course of action reasonably calculated to
to that court for trial, praying that the record of the case be remanded bring out the truth.
to the justice of the peace court of Masantol, the court of origin, in order
The foregoing decision was rendered by a divided court. The minority
that the petitioner might cross-examine the complainant and her
went farther than the majority and denied even any discretion on the
witnesses in connection with their testimony, on the strength of which
part of the justice of the peace or judge holding the preliminary
warrant was issued for the arrest of the accused. The accused, assisted
investigation to compel the complainant and his witnesses to testify
by counsel, appeared at the preliminary investigation. In that
anew.
investigation, the justice of the peace informed him of the charges and
asked him if he pleaded guilty or not guilty, upon which he entered the Upon the foregoing considerations, the present petition is dismissed
plea of not guilty. Then his counsel moved that the complainant present with costs against the petitioner.
her evidence so that she and her witnesses could be examined and
cross-examined in the manner and form provided by law. The fiscal and
the private prosecutor objected, invoking section 11 of rule 108, and
the objection was sustained. In view thereof, the accused's counsel
announced his intention to renounce his right to present evidence, and
the justice of the peace forwarded the case to the court of first instance.

ISSUE:
Whether or not the Justice of the Peace court of Masantol committed
grave abuse of discretion in refusing to grant the accused's motion to
return the record.