ACTS: A libel case was filed against Carson Taylor, who was the acting editor, proprietor, manager,

printer
and publisher of a Manila Daily Bulletin. The complaint alleges that he, on September 25, 1913, intended to
impeach the honesty, virtue and reputation of Ramon Sotelo as well as to expose him to public hatred, contempt
and ridicule by composing, printing, editing, publishing, circulating and/ or procuring to compose an article,
which they have alleged to be false and to be a malicious defamation and libel of

Ramon Sotelo. According to the article entitled “Owners fired building to collect insurance, criminal charges
follows civil suit”

, there was a conspiracy to defraud the insurance company. The house in Calle

O’Donnell was intentionally burnt and claims were made from the insurance companies. In this

conspiracy, the name of Ramon Sotello was implicated and was therefore charged with conspiracy and fraud.
Taylor was found guilty and sentenced to pay a fine of P200.He then appealed and made assignment of errors.

ISSUES:

1. Whether or not the defendant was responsible for and guilty of alleged libel

2. Whether or not the defendant is the proprietor and publisher of Manila Daily Bulletin

HELD: The court ruled in favor of the defendant and ordered that the ruling of the lower court be

reversed. According to Act No. 277 Section Six, “every author, editor or proprietor of any book,

newspaper, or serial publication is chargeable with the publication of any words contained in any part

of said book or number of each newspaper or serial as fully as if he were the author of the same.”

However, in this case, the Solicitor-General said that no one is represented to be the author, editor and
proprietor. There was no word of proof in the record showing that he was either the author, editor or proprietor.
It only mentioned that the defendant was the manager. There was no proof that he as the manager was directly
responsible for writing, editing or publishing the contents in the alleged libelous article. The prosecution only
presented the newspaper to show the relationship of the defendant to it. However, this only proves the
relationship between the defendant and the publication. In the absence of proof of a single letter showing the
direct relationship and role of the defendant on the publication of the said article, presumptions of his
involvement would be unwarranted and unjust.

***FACTS:On September 25, 1913, Carson Taylor, the acting editor and proprietor,manager, printer and
publisher of the Manila Daily Bulletin, a paper of large circulationthroughout the Philippines, in the United
States and other countries, did then and therewillfully, unlawfully, feloniously, maliciously and with intent to
impeach the honesty, virtueand reputation of Ramon Sotelo, who was a member of the Philippine bar. A
certainfalse and malicious defamation and libel in the English language of and concerning thesaid Ramon
Sotelo, was entitled, “OWNERS FIRED BUILDING TO COLLECTINSURANCE - CRIMINAL CHARGES
FOLLOWS CIVIL SUIT.” As written in the saidarticle, there was a conspiracy to defraud the insurance
company and the building wasfired to collect the amount of insurance. The movable furniture of value was
removedbefore the fire and the full amount of the insurance was collected, and the conspiracywas a success.
Implicated in the charges of conspiracy and fraud is the name of the

People v SantiagoGR No. 175843/8/1922Justice Romualdez

FACTS:Santiago was driving an automobile at high speed, notwithstanding the fact that he had to pass anarrow
space between a wagon standing on one side of the road and a heap of stones on the other side where two boys
standing. He ran over Parondo who was instantly killed as a result of theaccident.Santiago was convicted by the
lower court of the crime reckless imprudenceThe accused appealed by challenging the validity of Act No. 2886
which amended General Order no. 58.

ISSUE:Whether or not Act No. 2886 which amended General Order no. 58 is valid?
HELD:YesRatio:The Government has the right to use police power, creating and defining criminal offenses. It
isurged that the right to prosecute and punish crimes is an attribute of sovereignty, but by reason of principle of
territoriality.The Philippine Legislature by the virtue of Jones Law has the power to define and punish
crimes.Philippines is autonomous created by the US congress.Power of legislature to prescribe the form of the
criminal complaint as long as the constitutional provision of the accused to be informed the nature of the
accusation is not violated.

***People Vs. Santiago

FACTS:Petitioner Gregorio Santiago caused the death of a 7year old boy by striking himwith an automobile
that he was driving. Santiago was prosecuted for the crime of homicide by reckless negligence, Santiago does
not agree with the courts sentence,questioning the constitutionality of act no. 2886 amending order no. 58
stating thatall prosecutions for public offenses shall be in the name of the U.S... Act no. 2886stating that all
prosecutions for public offenses shall be in the name of thePhilippine islands.

ISSUE:Whether the procedure in criminal matters is incorporated in the constitution of thestate?

HELD:NO, procedure in criminal matter is not incorporated in the constitution of thestates, but it is left in the
hand of the legislature, so that it falls within the realm of public statutory law.It is limited to criminal procedure
and its intention is to give to its provision theeffect of law in criminal matters.In pursuance of the constitution of
the US each state has the authority, under itspolice power rule to define and punish crimes and to lay down the
rules of criminalprocedure. The delegation to our government needs no demo, the crimes committed w in
ourterritory even before sec 2 of general orders no.58 was amended, were prosecutedand punish jurisdiction
.Act no. 2886 (feb 24 1920) criminal complainant was filed may 10 1920. The silenceof congress regarding
those laws amendatory of the said general orders must beconsidered as an act of the approval.