G.R. No. L-6013
THE UNITED STATES, plaintiff-appellee, vs. FELIPE TRIA, ET AL., defendants-appellants.
November 15, 1910

FACTS:
The defendants-appellants, Felipe Tria, et al., were among 78 persons charged with a criminal violation of the Election Law for voting at the general election on November 2, 1909, without possessing the qualifications required by law. Fifty-three of the accused were convicted and sentenced, and they subsequently appealed.

Section 13 of the Election Law outlines the voter qualifications: a male person 23 years or older, with 6 months legal residence in the municipality, not a foreign citizen, and falling into one of three classes: (a) held specific municipal offices prior to August 13, 1898; (b) owned real property worth P500 or annually paid P30 or more in establishment taxes; or (c) could speak, read, and write English or Spanish.

The prosecution presented evidence to demonstrate that none of the appellants met any of these qualifications. Witnesses testified that appellants had not held the specified prior offices (a), nor could they speak, read, and write English or Spanish (c). Treasury officials confirmed through tax books that none of the appellants owned property valued at P500 or more, nor did they pay P30 or more in annual taxes (b). The prosecution argued that while proving a negative was difficult, they presented the best evidence obtainable, as the appellants themselves failed to produce evidence of their qualifications.

ISSUE:
Can a conviction for unlawfully voting (without qualifications) stand when the prosecution proves the lack of qualifications, and the defendants fail to present evidence to rebut the presumption of full knowledge and criminal intention?

RULING:
Yes. The Supreme Court affirmed the judgment of conviction.

The Court held that when the prosecution proves that the appellants committed the unlawful acts charged (i.e., voting without legal qualifications), it is properly presumed that the acts were done with full knowledge and with criminal intention. It was then incumbent upon the appellants to rebut that presumption. Since the appellants failed to do so, their convictions must stand.

The Court reasoned that the prosecution successfully established, prima facie, that the appellants did not possess any of the required voter qualifications through witness testimonies and official records. While the burden was on the prosecution to prove a negative, they presented the best evidence available under the circumstances, noting that the “best or the completest evidence” of qualifications was within the appellants’ control, which they “refused to produce, or, at least, refrained from producing.” The law requires only that the prosecution establish a prima facie case. Once an unlawful act is proven, the general criminal intent and guilty knowledge are presumed by law from the act performed. It is for the accused to present facts demonstrating an honest mistake of fact or other circumstances that would rebut this presumption. Having failed to offer any such rebuttal evidence, the convictions were proper.