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People v. Santiago

Gregorio Santiago was prosecuted for homicide by reckless negligence after causing the death of a child with his car. He questioned the constitutionality of a law that amended how criminal prosecutions are conducted, changing it from the name of the United States to the People of the Philippine Islands. The court ruled the amendment was valid and within the authority of the legislature, as each state has the power under its police powers to define, punish crimes, and set criminal procedures.

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164 views1 page

People v. Santiago

Gregorio Santiago was prosecuted for homicide by reckless negligence after causing the death of a child with his car. He questioned the constitutionality of a law that amended how criminal prosecutions are conducted, changing it from the name of the United States to the People of the Philippine Islands. The court ruled the amendment was valid and within the authority of the legislature, as each state has the power under its police powers to define, punish crimes, and set criminal procedures.

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Power/Authority of the State to Punish Crimes Case # 1

Source: 1987 Constitution

People v. Santiago

43 Phil. 120 (1922)

FACTS:

Gregorio Santiago was prosecuted for the crime of homicide by reckless negligence,
having caused the death of a 7-year-old boy by striking him with an automobile that he was
driving. Santiago does not agree with the court's sentence, and questioned the constitutionality
of Act No. 2886, amending Order No. 58 which states that “all prosecutions for public offenses
shall be in the name of the United States against the persons charged with the offenses.” Act
No. 2886 states that “all prosecutions for public offenses shall be in the name of the People of
the Philippine Islands against the persons charged with the offense.”

ISSUE: Whether or not Act No. 2886 is valid and constitutional

RULING: Yes

RATIO DECIDENDI: Since the provisions of this General Order (No. 58) have the character of
statutory law, the power of the Legislature to amend it is self-evident, even if the question is
considered only on principle. Our present Legislature, which has enacted Act No. 2886, the
subject of our inquiry, is the legal successor to the Military Government as a legislative body.
Each State has the authority, under its police power, to define and punish crimes and to lay
down the rules of criminal procedure. It is urged that the right to prosecute and punish crimes
is an attribute of sovereignty.

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