GR L 4689; (August, 1908) (Digest)

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📖 Full Court Text ⚡ Case Digest 🕵️ Case Critique

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📌 CORE DOCTRINE

“A conviction under a specific statutory provision for possession of opium paraphernalia remains valid even if evidence presented at trial includes acts covered by a different provision, as long as the elements of the charged offense are proven.”

💡 PLAIN ENGLISH SUMMARY

Go Tiao was found guilty of having illegal opium equipment because a witness saw him with it, and the court said that's enough to convict him, even though the witness also mentioned seeing him smoke opium. The key point is that the charge was about possessing the equipment, not necessarily using it, so the extra details about smoking didn't change the guilty verdict.

📜 LEGAL MAXIM

Actus non facit reum nisi mens sit rea | Falsus in uno, falsus in omnibus

VERIFIED AI SNAPSHOT FOR ARMZTRONG.ORG

FACTS:
Go Tiao (alias Suya), the defendant-appellant, was charged with having in his possession opium pipes and other apparatus for using opium, without the necessary prescription from a physician or permit from the Collector of Internal Revenue. During the trial, a witness for the prosecution testified not only that he saw the specified opium paraphernalia in the possession of the accused but also that he had seen the accused smoking opium. The lower court sentenced Go Tiao to six months in the provincial jail and payment of costs.

ISSUE:
Whether the complaint was properly framed under Section 7 of Act No. 1761 (possession of opium paraphernalia) given that the prosecution witness also testified to seeing the accused smoking opium, which would fall under Section 4 of the same Act.

RULING:
The Supreme Court affirmed the conviction. The Court held that inasmuch as the witness also testified that he saw the specified objects (opium pipes and apparatus) in the possession of the accused, the complaint framed under Section 7 of Act No. 1761 and the subsequent conviction were proper, regardless of the additional testimony regarding opium smoking. The sentence of the court below was affirmed.

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