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ATIENZA - THE UNITED STATES, Plaintiff-Appellee

The defendant was accused of violating the Internal Revenue Law by failing to record business activity for one day in his printing establishment's log book, as required. He was convicted and fined. The Supreme Court overturned the conviction, finding that the defendant employed a bookkeeper to maintain the logs, and there was no evidence the defendant knew the one day had not been recorded. The Court held that penal statutes must be strictly construed, and one cannot be held criminally liable for the unauthorized acts of another unless a statute specifically requires it. The defendant was acquitted.

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0% found this document useful (0 votes)
13 views2 pages

ATIENZA - THE UNITED STATES, Plaintiff-Appellee

The defendant was accused of violating the Internal Revenue Law by failing to record business activity for one day in his printing establishment's log book, as required. He was convicted and fined. The Supreme Court overturned the conviction, finding that the defendant employed a bookkeeper to maintain the logs, and there was no evidence the defendant knew the one day had not been recorded. The Court held that penal statutes must be strictly construed, and one cannot be held criminally liable for the unauthorized acts of another unless a statute specifically requires it. The defendant was acquitted.

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vhee
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STATUTORY CONSTRUCTION

Atty. John Paul Nanit

1. THE UNITED STATES, plaintiff-appellee,

vs. ANTONIO ABAD SANTOS, defendant-appellant.

TITLE THE UNITED STATES, plaintiff-appellee,


vs.
ANTONIO ABAD SANTOS, defendant-appellant.
GR NUMBER G.R. No. L-12262

DATE February 10, 1917

PONENTE MORELAND, J.:

NATURE/KEYWORDS

FACTS

● The appellant here is accused of violating the Internal


Revenue Law. He was convicted and sentenced to pay a fine
of P10. He appealed.

● Section 185 of Act No. 2339 (now section 2727 of the


Administrative Code)

● The appellant is the owner of a printing establishment called


"The Excelsior" and as such was required by law to keep a
book in which he should make the entries required by the
above quoted regulation. It is charged in the information that
he violated the provisions of said... regulation in that he
failed to make any entry for the 5th day of January, 1915,
indicating whether any business was done on that day or not.

ISSUE(S)
1. Won the appellant is guilty of violating the Internal Revenue
Law.

RULING(S) No. The appellant must be acquitted. It is clear that the appellant had
employed a bookkeeper to be in-charge, and he took no part in
keeping the book in question. Therefore, the appellant knew nothing.
Penal Statutes are to be strictly construed and courts will not
hold a person criminally responsible for the acts of another,

STATUTORY CONSTRUCTION - CASE DIGEST ATIENZA, V.


committed without his knowledge or consent, unless there is a statute
requiring it.

The judgment of conviction is reversed and the accused acquitted.

DOCTRINE/PRINCIPLES

STATUTORY CONSTRUCTION - CASE DIGEST ATIENZA, V.

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