West Coast Life Insurance vs Geo Hurd

written by Howard

G.R. No. L-8527 – 27 Phil. 401 – Mercantile Law – Corporation Law – No Criminal Actions Against A Corporation 

In 1912, West Coast Life Insurance caused the distribution of printed materials which impressed among the readers thereof that Insular Life Insurance Company is in bad shape. Insular Life then filed a criminal case for libel against West Coast Insurance. Judge Geo Hurd took cognizance of the case.

West Coast Insurance opposed the same as it alleged that the filing was against prevailing rules of criminal procedure.

ISSUE: Whether or not West Coast Life Insurance is correct.

HELD: Yes. There is no provision in the prevailing rules of criminal procedure to support the said criminal case filed against West Coast Life Insurance. A corporation cannot be proceeded against criminally in court primarily because a corporation cannot possibly commit a crime absent the essential element of malicious intent. The rule is to proceed against the officials of the corporation and not the corporation itself.

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