U.S. v.

Go Chico directed
G.R. No. 4963, September 15, 1909

FACTS:
On or about August 4, 1908, appellant Go Chico displayed on the window
of his store, No 89 Calle Rosario, medallions in form of small buttons,
upon which were faces of Emilio Aguinaldo, and the flag or banner or
device used during the late insurrection of the Philippine Islands to
designate the identify those in armed insurrection against the United
States. Prior to the day aforementioned, appellant had purchased the
stock of goods in said store, of which the medallions formed part, at a
public sale made under authority of the sheriff of the city of Manila. On
August 4, appellant was arranging his stocks for the purpose of displaying
them to the public, placing them in his showcase and in one of the
windows of his store.

The appellant states he was ignorant of the law against the display of the
medallions and adds that he had no corrupt intention. He was charged in
violation of Sec. 1 of Art. 1696 of the Philippine Commission which
provides:
Sec. 1 – Any person who shall expose, or cause or permit to
be exposed, to public view on his own premise, or who shall
expose, or cause to be exposed, to public view, either on
his own premises or elsewhere, any flag, banner, emblem, or
device used during the late insurrection of the Philippine Islands
to designate or identify those in armed rebellion against the
United States, or any flag, banner, emblem, or device used or
adopted at any time by the public enemies of the United
States in the Philippine islands for the purposes of public
disorder or of rebellion or insurrection against the authority
of the United States in the Philippine Islands, or any flag,
emblem, or device of the Katipunan Society, or which is
commonly known as such, shall be punished by a fine not less
than 500 pesos nor more than 5,000 pesos, or by
imprisonment for not less than 3 months nor more than 5
years, or by both such fine and imprisonment, in the discretion of
the court.

Go Chico moved to acquit himself on the grounds that (1) c riminal intent
must be proven beyond reasonable doubt upon the part of the
accused before being convicted and; (2) the prohibition of the law is
against the use of the identical banners, devices, or emblems actually
used during the Philippine insurrection by those in armed rebellion
against the United States.

ISSUE:
WON intent is necessary in crimes punishable by special laws

HELD:
NO.
In the opinion of this court it is not necessary that the appellant should
have acted with the criminal intent. In many crimes, made such by
statutory enactment, the intention of the person who commits the crime
is entirely immaterial. If it were not, the statute as a deterrent influence
would be substantially worthless.

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.