U.S.

v Dorr

Summary:

The case at hand is one of an allegedly libelous editorial article against the Government of the
United States and the Insular Government of the Philippines, as defined by Act No. 292, Sec 8 of the
Commission. It is ruled that the article, although abusive of the members of the United States
Philippine Commission, does not constitute libel against the government itself and thus does not fall
under Act 292.

Facts:

Respondents were alleged to have committed an offense of writing, publishing and

circulating scurrilous libel against the Government of the U.S. and the Insular Government of
the Philippine Islands in violation of Section 8, Act 292 of the Commission.
The alleged libel was published in Manila Freedom issue dated 06 April 1902 as an
editorial issue on the appointment of "rascal natives" (Filipinos) to important Government
positions by the Civil Commission.
A question arises as to whether the term the Insular Government of the Phil.
Islands, as used in Section 8, Art. 292, refers to the existing law and institutions of the
Islands or the aggregate of the individuals by whom the government of the Islands is
administered.

Issue:
WON the Manila Freedom's editorial article violates Art. 292.
NO
The Sedition Act of 1798 used the term "government" in an abstract
sense meaning the existing political system, its laws, and its institutions. The court
rules that it is used similarly in Art. 292.
The editorial article in question attacks not the "government" as
used in Art 292, but the character of men who are entrusted with the administration of
the government. Therefore, the publication does not constitute any "seditious
tendency" in violation of Art. 292.