Lessons Applicable: Corporate Criminal Liability (Corporate Law)
FACTS:
- West Coast Life Insurance, a foreign life insurance corporation doing business regularly and legally in the Philippine Islands pursuant to its laws
- Plaintiff in CFI criminal action together with:
- John Northcott - general agent and manager for the Philippines
- Manuel C. Grey - was an agent and employees and acting in the capacity of treasurer of the branch
- Charged for printing, publish and distributing a large number of circulars to policy holders and prospective policy holders of Insular Life Insurance Co. stating that the rumor about it is true regarding it being in a bad shape and it capital has diminished
ISSUE: W/N West Coast Life Insurance should also be criminally charged.
HELD: NO.
- Provisions clearly indicate that the maker of the code of Criminal Procedure had no intention that corporations would be included
- Court only authorized to issue order of arrest; Court derives no authority to bring corporations before them in criminal actions nor to issue processes for that purpose
- Corporation = lack of malicious intent
