1CONSTI I: Case 81Case 81: United States vs. Fred L. DorrFacts: 5/23/1902, Defendants were charged with publication of false and malicious libel against Seor Benito Legarda (US Philippine commissioner) by placing certain headlines or caption above an article published in Manila Freedom, newspaper in Manila owned by defendant. The headline read Traitor, seducer, and perjurer . . .Defendants were found guilty of the of the offense charged in the complaint, and each was sentenced to six months imprisonment at hard labor and a fine of $1,000. They however, appealed their case to the SC. Defendants also asked that they be granted a trial by jury, provided for by Art. 3, sec 2 of the US constitution, under sixth amendment to the constitution. This motion was denied by court. The Philippines did not become a part of the United States, it merely became a territory belonging to the United States. This was from the cession of Spain to the US. Defendants also argued the validity of the anti libel law passed by the Philippine Commission, questioning their authority to pass laws.Issue:Is the Philippines, under the control of the United States, through treaty of Paris, also subject to the provisions of the constitution of the United States? This centers mainly on jury trials, as provided for in US constitution for criminal cases.

Held: The government and laws of the US does not extend to a territory acquired by the US by mere act of cession. Phil. Bill of 1902 extends nearly all of the provisions of the US constitution pertaining to the Bill of Rights, but it did not include provisions relating to Jury Trials (article III, and 6th amendment) Provisions in the constitution for trial by jury are not self executing, they need legislation for it to be executed (needs laws prescribing qualifications of jury duty, etc.) Philippine commission is a body expressly recognized and sanctioned by act of Congress, having power to pass lawsThe court, came to a decision, that the Philippines, is different to that of the United States, it is not a state, but merely a territory ceded to it by the crown of Spain. The treaty of Paris, did not automatically extend the US constitution to the Philippines, because mere act of cession will not automatically extend to an acquired territory, its status has to be determined by congress. What is extended, however, are those personal rights formulated in the constitution and its amendments (the bill of rights). These exist by inference and the general spirit of the constitution, and the right to trial by jury is not extended through mere act of cession of the territory. Congress, on the other hand, had not passed any laws for that matter extending the provision of the constitution relating to jury trials. On the matter of commission of libel, the court found defendants to be guilty of such crime, for providing a false article, that which does not come from the privileged report. Such article was meant to insult and injure Seor Legarda. Judgment of CFI should be affirmed, with costs against defendants.