G.R. No. L-6160 / March 21, 1911
THE UNITED STATES vs. DANIEL NAVARRO, ET AL.

FACTS

The appellants were convicted for violating Section 30 of the Election Law (Act No. 1582) by falsely swearing before an election officer in Piddig that they owned real property worth ₱500, a qualification required to vote in the November 2, 1909 elections. The prosecution’s evidence focused on the assessed value of the appellants’ properties. All appellants except Daniel Navarro and Genaro Calixto failed to prove ownership of real property with an assessed value of at least ₱500. Navarro and Calixto, however, presented proof that they owned real estate with an assessed value exceeding ₱500.

ISSUE

Whether the “property qualification” for voters under the Election Law refers to the assessed value (for tax purposes) or the actual/market value of the real property owned.

RULING

The Supreme Court AFFIRMED the convictions of all appellants except Daniel Navarro and Genaro Calixto, whose acquittal was ordered. The Court held that the property qualification under the Election Law is based on the assessed value of real property, not its market value. This interpretation is derived from:
1. The statutory structure linking the property qualification with tax payment qualifications, where taxes are levied based on assessed value.
2. The disqualification of delinquent taxpayers, which would be anomalous if unassessed property could qualify a voter while tax delinquency on assessed property could disqualify another.
3. Practical necessity: requiring proof of market value would cripple election administration, as electoral boards and courts could not efficiently verify qualifications within statutory timeframes.

Thus, ownership of real property with an assessed value of ₱500 is the statutory requirement. Navarro and Calixto met this standard and were acquitted. The fines for the convicted appellants were modified to allow extinguishment at one day’s imprisonment per ₱2.50 of the fine.