US v Go Chico case digest

U.S. v. Go Chico 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) criminal intent must be proven beyond reasonable doubt upon the part of the accused before being convicted and; (2) the prohibition of the law is directed

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.