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CASE DIGEST · CRIMINAL LAW I

US vs. Taylor

October 25, 2017October 25, 2017 · LEGIStrata

THE UNITED STATES, plaintiff-appellee, vs. CARSON TAYLOR, defendant-appellant.
G.R. No. L-9726 December 8, 1914

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 A y. Ramon Sotelo was published in said newspaper which implicated that there
had been conspiracy and fraud between said a orney and owner of the burnt building so as to collect
insurance. A y. Sotelo further contended that the article was of a certain false and malicious defamation
and libel. The CFI agreed to A y. 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,
although libel is made a crime, the defendant is not the author, editor, or proprietor of the said
newspaper—instead, only its manager. Neither does the proof show in the record that the manager
played a part in the publication of the article.

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28 PHIL 599 CASE DIGEST COMMON LAW CRIMES IN PHILIPPINES CRIMINAL

LAW I DECEMBER 8 1914 G.R. NO. L-9726 US VS. TAYOR