G.R. No. 17584 ; March 8, 1922
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. GREGORIO SANTIAGO, defendant-appellant.

FACTS

Gregorio Santiago was prosecuted for homicide by reckless negligence after the automobile he was driving struck and killed a 7-year-old boy, Porfirio Parondo. He was convicted and sentenced to one year and one day of prision correccional. On appeal, Santiago argued that the trial court lacked jurisdiction because the prosecution was based on Act No. 2886 , which amended General Orders No. 58 by changing the title of criminal prosecutions from “the United States” to “the People of the Philippine Islands.” He contended that Act No. 2886 was unconstitutional, as the Philippine Legislature allegedly lacked authority to amend General Orders No. 58, which he claimed had the character of constitutional law.

ISSUE

Whether Act No. 2886 , which amended Section 2 of General Orders No. 58, is constitutional and valid.

RULING

Yes, Act No. 2886 is constitutional and valid. The Philippine Legislature had the authority to enact it. General Orders No. 58 pertains to criminal procedure, not constitutional law. Under the police power delegated by Congress, the Legislature could define crimes and prescribe criminal procedure. The U.S. Congress’s failure to annul Act No. 2886 after it was forwarded constituted implied approval. Any defect in the information’s title was merely formal and waived if not objected to at trial. The conviction was affirmed, with additional penalties imposed.