G.R. No. L-8527; March 30, 1914
WEST COAST LIFE INSURANCE CO. vs. GEO N. HURD, Judge of Court of First Instance

FACTS:
The petitioner, West Coast Life Insurance Co., is a foreign corporation organized under the laws of California and legally doing business in the Philippines. On December 16, 1912, an information for libel was filed in the Court of First Instance of Manila against the corporation and its officers, John Northcott and Manuel C. Grey. The court issued a summons directing them to appear and answer the charge. The corporation moved to quash the summons, arguing that the court lacked jurisdiction to proceed against a corporation in a criminal action. The motion was denied, and the court ordered the corporation to appear and plead. The corporation then filed this action for a writ of prohibition to restrain the respondent judge from further proceedings in the criminal case, contending that the court had no authority to issue criminal process against a corporation.

ISSUE:
Whether a corporation may be proceeded against criminally and subjected to criminal process under the laws then in force in the Philippines.

RULING:
No. The Supreme Court granted the writ of prohibition, holding that the Court of First Instance had no jurisdiction to issue criminal process against a corporation. The courts in the Philippines are statutory creations and possess only those powers expressly or impliedly conferred by statute. They have no common law jurisdiction. Under the Spanish criminal law and procedure, which influenced Philippine law, a corporation could not be criminally prosecuted as such, especially for crimes requiring willful or malicious intent. Since no statute authorized criminal proceedings against corporations or provided a procedure for such actions, the court acted without authority. The criminal action could proceed only against the individual officers, not the corporation itself. The respondent judge was therefore enjoined from further proceedings against West Coast Life Insurance Co. in the criminal case.