G.R. No. L-6128, March 23, 1911
THE UNITED STATES vs. SILVESTRE ARZADON

FACTS

Silvestre Arzadon was charged with violating the Election Law. On registering as an elector for the November 1909 elections in Badoc, Ilocos Norte, he took an oath before a member of the municipal electoral board that he was not delinquent in paying the land tax on his properties, when in fact he was. Arzadon admitted the charge but defended himself by alleging that the board of election inspectors, through a formal resolution in response to his own protest, had declared that tax-delinquent individuals could register as electors, provided they paid their taxes before election day. He claimed he relied on this resolution when he decided to register.

ISSUE

Whether Arzadon’s reliance on the election inspectors’ resolution exempts him from criminal liability for having falsely sworn that he was not tax-delinquent.

RULING

No. The Supreme Court affirmed his conviction. While Arzadon may have believed in good faith that he could register despite his tax delinquency based on the inspectors’ resolution, this did not negate the essential element of the crime. The charge was specifically for falsely swearing that he was not delinquent when he knew he was. His own confession established that he was fully aware of his delinquency at the time he took the oath. Good faith or inducement by others cannot be invoked for a fact that was personally and certainly known to be false. His act fell squarely within the prohibition of paragraph 4, Section 30 of the Election Law. The trial court’s sentence of a P200 fine was affirmed, but the subsidiary imprisonment was modified in accordance with the law.