G.R. No. 9073 ; September 11, 1914
THE UNITED STATES, plaintiff-appellee, vs. MONICO CUSTAN, defendant-appellant.

FACTS:
Monico Custan was convicted in the trial court for violating the Election Law. The information alleged that on May 3, 1912, he took the elector’s oath required by law despite being delinquent in the payment of his personal cedula tax in the amount of P1.23. At trial, Custan essentially admitted the act but offered an excuse, claiming he did not understand the requirements of the law and was awaiting advice from the municipal treasurer on the amount due. He paid the delinquent tax on June 29, 1912, nearly two months after taking the oath. The trial court imposed a fine of P200.

On appeal, Custan raised procedural errors, arguing that: (1) he was not properly identified in court; (2) his arraignment did not comply with General Orders No. 58; and (3) the record did not show he was provided with or informed of his right to counsel.

ISSUE:
Whether the alleged procedural irregularities in Custan’s trial constitute reversible error warranting the reversal of his conviction.

RULING:
The Supreme Court affirmed the conviction and found no reversible error.

1. On Identification: The Court held that Custan’s answers during his examination at trial impliedly admitted his identity as the person named in the information.

2. On Arraignment: The record showed that at the opening of the trial, the judge addressed Custan regarding the charge, and Custan responded by stating he did not wish to plead guilty or not guilty but wanted to explain his side. The Court ruled that this sufficiently showed Custan was arraigned, given an opportunity to plead, and was fully advised of the charge against him. Any informality in the procedure did not prejudice his substantial rights and was, at most, an error without prejudice.

3. On Right to Counsel: Citing prior jurisprudence (United States v. Labial and Abuso, 27 Phil. Rep., 82), the Court held that the mere failure of the record to affirmatively show that the accused was advised of his right to counsel is not, by itself, reversible error, especially where it does not appear that his substantial rights were prejudiced.

The Court took the opportunity to admonish trial courts and their officers against laxity and informality in criminal proceedings and in the preparation of records. It emphasized the utmost importance of strict compliance with procedural rules and the need for records to affirmatively and completely disclose all incidents of the trial to ensure the due administration of justice. However, since the alleged irregularities did not prejudice Custan’s rights, the judgment of conviction was affirmed.