G.R. No.: L-12262
Title: The United States vs. Antonio Abad Santos

FACTS:
Antonio Abad Santos, the owner of a printing establishment called “The Excelsior,” was charged with violating the Internal Revenue Law for failing to make the required daily entry in his day book for January 5, 1915, as mandated by Circular No. 467 issued by the Collector of Internal Revenue. The circular required businesses to keep a day book detailing daily cash receipts, with entries made within 24 hours, and to note if no money was received on any given day. Abad Santos was convicted and fined P10. On appeal, it was established that he had employed a bookkeeper who was solely responsible for maintaining the book, and the omission was due to the bookkeeper’s negligence, without Abad Santos’s knowledge, direction, or consent.

ISSUE:
Is a business owner criminally liable for the failure of his employee (bookkeeper) to make the required entries under the Internal Revenue Law, when the owner had no knowledge of or participation in the omission?

RULING:
No. The Supreme Court acquitted Antonio Abad Santos. The Court held that criminal liability for the acts of another requires clear statutory intent. Neither Act No. 2339 (the Internal Revenue Law) nor Circular No. 467 expressly imposed criminal liability on a principal for the unauthorized omissions of an employee. Since Abad Santos had no knowledge of or involvement in the bookkeeper’s failure to make the entry, and there was no evidence of connivance or direction, he could not be held criminally responsible. Criminal statutes must be strictly construed, and liability cannot be extended beyond clear legislative intent. The conviction was reversed, and Abad Santos was acquitted.