TITLE: US VS TAYLOR

FACTS:

 Carson Taylor was guilty of libel for an article published in “Manila Daily Bulletin” owned
by the “Bulletin Publishing Company”
 The article was about a conspiracy of a building burnt intentionally in order to defraud an
insurance company
 Mr Taylor appealed to the court and made the six (6) assignments of error of which two
(2) were deemed necessary to be discussed by the court, and these are as follows:
o First. The court erred in finding that the defendant was responsible for and guilty
of the alleged libel;
o Second. The court erred in finding that the defendant was the proprietor and
publisher of the “Manila Daily Bulletin”
 Mr Taylor presented that he was “manager” of the publishing company and not author,
publisher, or proprietor
 No evidence was presented to the court to prove that Mr Taylor was working as an
author, publisher, or proprietor
ISSUE:
Whether or not Mr Taylor is guilty under Act No. 277 of the United States Philippine
Commission
RULING:
Act No. 277 of the United States Philippine Commission:
“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.”
ANALYSIS/APPLICATION:
As discussed in the case, the burden of proof is born by the plaintiff. In this case, Mr
Taylor has asserted that he is the “manager” of the publishing company (“Bulletin Publishing
Company”) and not the author, editor, or proprietor of the article. Although the word “manager”
is of general use, there has been no presented proof to ascertain that the defendant is the
author, editor, or proprietor. There may be basis for the alleged crime (Act No. 277) of libel,
however, the lack of evidence could not prove that Mr Taylor is guilty.
Important: This case is linked to “No common law crimes in the Philippines” subtopic in
the RPC. In this case, the court mentioned that “in the Philippine Islands there exist no crimes
such as are know in the United States and England as common law crimes. No act constitutes a
crime here unless it is made so by law. Libel is made a crime here by Act No. 277 of the United
States Philippine Commision.”
CONCLUSION:
No, Mr Taylor is not guilty under Act No. 277 of the United States Philippine
Commission because there is no proof that him being the “manager” constitutes and relates to
being an author, editor, or proprietor.