G.R. No. L-6133, August 9, 1911
THE UNITED STATES, plaintiff-appellee, vs. MELECIO ESTAVILLO, ET AL., defendants-appellants.

FACTS

Fourteen defendants were charged with violating Section 30 of the Election Law (Act No. 1582) for knowingly taking a false oath as voters. They swore before the election board on September 24, 1909, that they were not delinquent in paying their land taxes for 1909, when in fact they were. Their names were subsequently registered in the voting list for the November 1909 general election. The defendants pleaded not guilty, each presenting excuses such as having delegated tax payment to relatives, being absent from town, believing their taxes were paid, or assuming the buyer of their land was responsible for taxes. The trial court convicted all defendants and sentenced each to a fine of P200, with subsidiary imprisonment at a rate of P2 per day in case of insolvency, plus a share of the costs.

ISSUE

Whether the defendants are criminally liable for violating Section 30 of the Election Law by taking a false oath regarding their tax delinquency, despite their claimed lack of knowledge or intent.

RULING

Yes, the defendants are criminally liable. The Supreme Court affirmed the conviction but modified the rate of subsidiary imprisonment. The Court held that the defendants’ excuses were insufficient to negate criminal intent. The law requires voters to know their tax status, and ignorance due to negligence (e.g., failing to verify payment after delegating it) does not excuse the violation. The defendants’ oaths were solemn declarations, and they could not evade responsibility by claiming they did not know they were delinquent when they had the means to ascertain the truth. The Court emphasized the need to enforce the Election Law strictly to uphold the integrity of elections.

Regarding the penalty, the Court applied the more favorable provision of Act No. 1732 (effective October 1, 1907), which governs subsidiary imprisonment for non-payment of fines. It set the subsidiary imprisonment at a rate of P2.50 per day for the fine only, not including costs, and limited such imprisonment to six months if only a fine is imposed. The judgment was affirmed with this modification.