As used in Act No.

292, the term "government" is used in the abstract

US v. Dorr sense of the existing political system, as distinguished from the
concrete organisms of the Government, such as the Houses of
Congress and the Executive, which are also specially mentioned. Had
Facts: Fred L. Dorr and a number of other persons (Dorr, et al.) the framers of the said law intended to mean specific government
were convicted of violating Section 8 of Act No. 292 which punishes personnel, they would have expressly stated so.
the utterance of "seditious words or speeches" and the writing,
publication, or circulation of "scurrilous libels against the In this case, the article in question, attacked the Civil Commission
Government of the United States or the Insular Government of the and some of its individual members, not the governmental system.
Philippine Islands" or other libels against the same entities which (1) Hence, it falls outside the purview of Act No. 292.
"tend to disturb or obstruct any lawful officer in executing his office",
(2) "tend to instigate others to cabal or meet together for unlawful
purposes", (3) "suggest or incite rebellious conspiracies or riots", or
(4) "tend to stir up the people against the lawful authorities or to
disturb the peace of the community, the safety, and order of the
Government". The same provision also punishes the deliberate
concealment of the aforementioned acts.

The charge against Dorr et al. stemmed from an article published in

the newspaper Manila Freedom criticizing the appointment by the
Civil Commission of certain persons— including Trinidad H. Pardo
de Tavera— to key government positions. The said article referred to
the aforementioned appointees as "rascals" and "corrupt" and called
certain government offices organized by the Civil Commission as
"rotten" and "corrupt".

Issue Whether or not the publication of the subject article falls

within the purview of Section 8 of Act No. 292.

Held No. The article in question produces none of the effects

enumerated in Section 8 of Act No. 292. In addition, the same
provision refers to libel of the government in general, and not of
specific individuals.

Ratio Decidendi N.B.: The Court did not provide any basis for
finding that the subject article did not have the tendency to produce
the effects enumerated under Section 8 of Act No. 292, other than all
the justices agreed on the same conclusion.