GR L 11162; (August, 1916) (Digest)

G.R. No. L-11162; August 12, 1916
THE UNITED STATES, plaintiff-appellee, vs. F. LULING, defendant-appellant.

FACTS:
On May 14, 1915, a complaint was filed in the Court of First Instance of Manila charging F. Luling, a wharf watchman employed in the customs service, with a violation of Section 316 of Act No. 355. The complaint alleged that on or about May 10, 1915, in Manila, the accused willfully and unlawfully solicited and received the sum of P100 from Rufino Elord. This payment was made to secure, through customs brokers, the importation and delivery to Elord of certain rolls of paper in which a large quantity of opium was hidden. After trial, the court found Luling guilty and sentenced him to pay a fine of P1,000, with subsidiary imprisonment in case of insolvency, and to pay the costs. The defendant appealed.

ISSUE:
1. Whether Section 316 of Act No. 355 is unconstitutional for allegedly violating the presumption of innocence by placing the burden of proof upon the accused to show that his act was innocent and without unlawful intent.
2. Whether the evidence adduced during the trial is sufficient to prove the guilt of the accused beyond a reasonable doubt.

RULING:
The Supreme Court affirmed the judgment of the lower court.

1. On the Constitutionality of Section 316: The Court held that the statutory provision is not unconstitutional. While the general rule in criminal law is that the prosecution must prove guilt beyond a reasonable doubt and the accused is presumed innocent, the legislature, within certain limitations, has the authority to define crimes and specify what proof shall constitute prima facie evidence of guilt. For statutory crimes, it is a valid exercise of legislative power to provide that proof of certain facts by the state shall be prima facie evidence of guilt, thereby shifting the burden to the defendant to explain that such acts were innocent and without criminal intent. The Court found that Section 316 does not violate any provision of the Act of Congress of July 1, 1902 (the Philippine Bill of 1902).

2. On the Sufficiency of Evidence: After a careful examination of the evidence, the Court found that the defendant, an employee in the customs service, did receive the sum of P100 from Rufino Elord in connection with the importation of goods. The money was not received for lawful duties or fees but was for the purpose of facilitating the illegal importation of opium. The evidence satisfied the prima facie case under Section 316, and the defendant failed to rebut the presumption of unlawful intent.

Therefore, the sentence of the lower court was affirmed, with costs against the appellant.