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Corporate Law Case Digest: West Coast Life Insurance Co. v. Hurd (1914)

G.R. No. L-8527March 30, 1914
Lessons Applicable: Corporate Criminal Liability (Corporate Law)

  • 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:
  1. John Northcott - general agent and manager for the Philippines
  2. 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.

  • 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