G.R. No. L-7973; August 16, 1913
THE UNITED STATES, plaintiff-appellee, vs. LIM POCO, defendant-appellant.

FACTS

Lim Poco was convicted for violating Section 31 of Act No. 1761 (the Opium Law) and fined P300. He was found in possession of 16 or 18 pills containing a small quantity of opium (about 0.4%), which he claimed to have purchased six years prior from a drug store for medicinal purposes, denying knowledge of their opium content. At trial, a pharmacist testified the pills were medicinal in nature but contained opium. Revenue agents testified that upon seizure, Lim Poco admitted knowing the pills contained opium, though he later denied this knowledge in court.

ISSUE

Whether Lim Poco’s possession of pills containing a minimal amount of opium, allegedly for medicinal purposes and without a physician’s prescription, constitutes a violation of the Opium Law, notwithstanding his claim of lack of knowledge regarding the opium content.

RULING

Yes. The Supreme Court affirmed the conviction. The Opium Law penalizes unauthorized possession of opium or its derivatives regardless of quantity or purpose, including medicinal use without a prescription. The claim of ignorance of the opium content is a defense, but the accused must prove it credibly. Here, Lim Poco’s story was improbable and contradicted by evidence of his prior admission to knowing the pills contained opium. The Court held that mere possession establishes guilt unless the accused raises reasonable doubt about awareness of the prohibited drug’s presence, which Lim Poco failed to do.