G.R. No. 4411
THE UNITED STATES, plaintiff-appellee, vs. RUFINO DELOSO, defendant-appellant.
August 31, 1908

FACTS:
In December 1904, Rufino Deloso, intending to vote in the municipal elections in Jimenez, swore under oath to the municipal secretary that he was a resident of Jimenez and eligible to vote. Subsequently, in December 1905, Deloso was elected municipal president of Oroquieta. His election in Oroquieta was protested on grounds of non-residency. In his defense in January 1906, Deloso swore before a notary public that he had been, and continued to be, a resident of Oroquieta since April 1902. Evidence presented included two documents: one (Exhibit A) where Deloso swore residency in Oroquieta, and another (Exhibit B) which was a municipal form where he swore residency in Jimenez for the 1904 elections. Further evidence showed Deloso consistently resided in Oroquieta since 1902 and never voted in Jimenez. The provincial fiscal filed a complaint charging Deloso with falsification of official documents. The trial court found him guilty under Article 311, in connection with Article 310, of the Penal Code, and sentenced him to four months of arresto mayor. Deloso appealed, alleging he signed Exhibit B without reading it and was unaware of municipal code provisions on residency for electors.

ISSUE:
Did Rufino Deloso commit the crime of falsification of a certificate by knowingly using a false statement of residency to exercise the right of suffrage?

RULING:
Yes. The Supreme Court affirmed the trial court’s judgment.
Deloso committed the crime of falsifying a certificate by making a false statement of residency to the municipal secretary of Jimenez (Exhibit B), knowing its contents to be false, in order to exercise his right of suffrage. His actual residency was in Oroquieta, as proven by his later sworn statement (Exhibit A) and other evidence. The document (Exhibit B), though not strictly a public document, belongs to the class of certificates whose falsification by a private individual is specifically punished by Article 311 of the Penal Code, in connection with Article 310. The Court rejected Deloso’s defense of signing without reading or ignorance of the law, citing Article 2 of the Civil Code that ignorance of the law does not excuse non-compliance, and noting his apparent intelligence and familiarity with the Municipal Code. The Court found that Deloso maliciously and knowingly used the false certificate. Therefore, Deloso was found guilty of falsification, and the penalty of four months of arresto mayor was affirmed.