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The alleged libel was published in “Manila Freedom” issue dated 06 April 1902 as an editorial issue.
The editorial is about the appointment of rascal natives (Filipinos) to important Government positions
by the Civil Commission (CC for brevity).
Issue: Whether the Article published by the respondents is in violation of the Art. 292 for it directly
attacks the U.S. government and the Insular Government of the Phil. Island?
Ruling: No. In modern political science, the term government is defined as “the institution or
aggregate of institutions by which an independent society makes and carries out those
rules…xxx…the government is the aggregation of authorities which rule a society (administration)”.
On the other hand, the Sedition Act of 1798, the term ‘government’ is used in an abstract sense (e.q.
President, Congress), meaning the existing political system, its laws and institutions. The Court
opines that it is in this sense that the term is used in the enactment (Art. 292) under consideration.
Hence, in Art. 292, the meaning of “Insular of the Government of the Phil. Islands” is the government
as a system, however, the article in questions attacks the ‘government’ as the aggregate of public
officials who run it.
The Court ruled that the article in question contains no attack upon the governmental system
of the U.S., by which the authority of the U.S. is enforced in these Islands per se. In this case, it is
the character of men who are entrusted with the administration of the government which the
writer wants to bring disrepute due to their motives, public integrity, and private morals and wisdoms
of their policy. The publication does not constitute any seditious tendency being apparent to be in
violation of Art. 292.