Professional Documents
Culture Documents
CFI denied the motion and ordered West Coast et.al. to appear before the court on Dec.
28, 1912. Hence, this petition.
ISSUES (HELD)
1) W/N the CFI can summon a corporation to answer for a criminal complaint (NO)
2) W/N the process in question was valid (NO)
RATIO
1) THEN-PREVAILING CODE OF CRIMINAL PROCEDURE DID NOT CONTEMPLATE
CORPORATIONS
Gen. Orders No. 58, 5: An information is "an accusation in writing charging a person
with a public offense." 6 provides for the amendment of the information when the name
of the accused is unknown. These and the other provisions relating to arraignment,
counsel, demurrers, and pleas, all indicate that the Code did not intend to include
corporations within the ambit of its provisions.
The only process authorized in the Code is an arrest. The provisions on arrest
contemplate the bodily seizure and confinement of a person.
The Code does not authorize the arrest or arraignment of a corporation. Since
Philippine courts have no common law jurisdiction, their jurisdiction is limited to that
prescribed in the statutes, either under American or Spanish criminal procedure. In the
Spanish law, corporations (or their closest analogues) cannot be charged criminally, as it
could not commit a crime with a willful purpose or malicious intent. Criminal actions
against corporations would have to be proceeded with against the officers of the
corporation and not against the corporation itself.
The cases cited by the prosecution all refer to instances where there was a statute
providing for the criminal liability of corporations and the procedure for prosecuting
them, or instances of common law jurisdiction. No case was cited which allowed a
corporation to be prosecuted without express provision of statute or common law
jurisdiction.
2) PROCESS IN QUESTION IS NOT AUTHORIZED BY LAW
As the Code of Criminal Procedure contemplates only arrests, the process issued by the
CFI could not have been valid, since, under the circumstances of their creation, the
authority of Philippine courts with respect to criminal matters is as expressly confined by
statute or which is necessary to imply from such authority in order to fully and
adequately carry out the express authority conferred.
The CFI has no authority to devise its own processes and procedure. This authority is
vested in the legislature.
Even if there are penal laws which may provide for criminal liability of corporations, it
cannot be said that courts are authorized to promulgate special processes and
procedures to implement these laws, when the legislature itself has neglected to do so.
Under the prevailing law, bringing criminal actions against corporations requires many
additions to the present criminal procedure. It is indeed the duty of courts to punish
criminals, but it is also their duty follow prescribed rules of procedure and not to proceed
in an unauthorized manner.
DISPOSITION: Petition granted. CFI prohibited from proceeding against West Coast.