U NITED S TATES V . L ULING (Mayumi) August 12, 1916 | Johnson, J. | PETITIONER : The United States RESPONDENTS : F, Luling SUMMARY : Luling was charged with violating Section 316 of Act No. 355 for accepting P100 from Rufino Elorz/Elord in exchange of importing certain paper rolls which contained opium. During this time Luling was a wharf watchman of the government. The lower court found him guilty of this violation. He then appeals to the SC alleging that the section was unconstitutional because it provided that certain facts would constitute prima facie evidence of guilt and that subsequently the burden of proof would shift to the accused. This means the accused would have to prove his/her innocence. Luling claims that this is against the constitutional provision that every man is presumed innocent until proven guilty. SC ruled that it is not because statutes can provide for what constitutes as prima facie evidence of guilt. When this happens, the burden of proof shifts to the accused to prove innocence. DOCTRINE : The State has a right to declare what acts are criminal, within certain well-defined limitation, and also has a right to specify what act or acts shall constitute a crime, as well as what proof shall constitute prima facie evidence of guilt, and then to put upon the defendant the burden of showing that such act or acts are innocent and were not committed with any criminal intent. FACTS: 1. In May 14, 1915, the prosecuting attorney of the city of Manila presented a complaint in the CFI of Manila charging Luling for violating section 316 of Act No. 355 of the US Philippine Commission. a. It was alleged that Luling, “being a wharf watchman employed in the customs service of the Government of the Philippine Islands, did, willfully, directly, unlawfully, and criminally, solicit of and receive from Rufino Elorz or Rufino Elord P100 in order that he might secure through customs brokers, the importation and delivery to the said Elorz or Elord, of certain rolls of paper in which a large quantity of opium was hidden” ( basically he was a wharf watchman who accepted P100 to import and deliver rolls of paper with opium to Elorz/Elord ) 2. Upon said complaint, Luling was arrested, arraigned, tried, and found guilty. 3. Luling appealed this case to the SC alleging that: a. the provisions of section 316 of Act No. 355, in so far as it requires the accused to prove his innocence, is unconstitutional; and b. the evidence adduced during trial does not show that he is guilty of the crime charged ISSUES: 1. WoN Section 316 of Act No. 355 providing that certain facts would equate to prima facie evidence of guilt and consequently giving the burden of proof to the accused to prove his innocence is against the constitution -- NO RULING: Its sentence is therefore hereby affirmed, with costs. So ordered.
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