G.R. No. L-8646; March 31, 1915
THE UNITED STATES, plaintiff-appellee, vs. BENITO SIY CONG BIENG and CO KONG, defendants. BENITO SIY CONG BIENG, appellant.

FACTS:
The defendants, Benito Siy Cong Bieng and his employee Co Kong, were convicted in the lower court for violating Section 7 of Act No. 1655 (the Pure Food and Drugs Act). Co Kong, while acting as the agent and employee in charge of appellant Siy Cong Bieng’s store (tienda), sold adulterated coffee mixed with peanuts and other substances in the ordinary course of business. The facts were established by a stipulation of facts agreed upon by both parties. It was admitted that Siy Cong Bieng was the owner of the store, that Co Kong was his duly installed agent, and that the sale of the adulterated and falsely branded coffee occurred in the regular course of business. Crucially, the stipulation also stated that Siy Cong Bieng “really had no knowledge” that his agent would sell such adulterated coffee, and that the coffee was not manufactured or put up with his knowledge. Siy Cong Bieng appealed his conviction, arguing he should not be held criminally liable for an act of his agent done without his knowledge or intent.

ISSUE:
1. Whether a conviction under the Pure Food and Drugs Act requires proof of the seller’s guilty knowledge of the adulteration or criminal intent to violate the statute.
2. Whether a principal/employer can be held criminally liable for the sale of adulterated goods by his agent/employee within the scope of employment, even without the principal’s knowledge of the adulteration.

RULING:
The Supreme Court AFFIRMED the conviction of appellant Benito Siy Cong Bieng.

1. On the Requirement of Guilty Knowledge or Criminal Intent: The Court ruled that for statutory offenses like those under the Pure Food and Drugs Act, where the legislature, on grounds of public policy and necessity, absolutely prohibits an act, the commission of the forbidden act itself constitutes the crime. The statutory definition of the offense does not include words like “knowingly” or “willfully.” Therefore, proof of the sale of adulterated goods is sufficient for conviction. It is not necessary to allege or prove guilty knowledge of the adulteration or a conscious intent to violate the law. The intent to commit the prohibited act (the sale) is sufficient; the intent to commit a crime (evil intent) is not an essential element under this Act.

2. On the Liability of the Principal for Acts of an Agent: The Court held the principal criminally liable for the acts of his agent committed within the scope of employment, even without the principal’s knowledge. The Court based this on:
The public policy and nature of the statute, which aims to protect public health. Holding only the immediate seller liable would defeat the law’s purpose, as proprietors could evade responsibility through agents.
The principle of absolute liability for forbidden acts, where guilty intent is not essential. The master is held responsible for the servant’s conduct on the same theory as civil liability.
* The interpretation of Section 12 of Act No. 1655, which states that the act of an officer, agent, or employee acting within the scope of employment shall be deemed the act of the “commercial or legal entity” they represent. The Court construed “commercial or legal entity” broadly to include a private individual engaged in business through agents.

DISSENTING OPINIONS:
Chief Justice Arellano and Justice Araullo dissented without a written opinion. Justice Moreland dissented briefly, stating he believed Act No. 1655 was not applicable to the case.