G.R. No. L-8983; March 7, 1914
THE UNITED STATES, plaintiff-appellee, vs. EULOGIO EDPALINA, defendant-appellant.

FACTS:
The defendant, Eulogio Edpalina, was convicted in the lower court for an offense related to taking an elector’s oath. The record shows that he entered a plea of “guilty.” However, upon examination, the Supreme Court found that his plea, when read together with his statements at trial, was not actually a plea of guilty to the essential elements of the offense charged. It was merely an admission that he had taken the elector’s oath on the date specified and that he had not paid his land taxes for the year 1911 at that time. The facts of this case are substantially similar to those in the earlier case of United States vs. Labadan (26 Phil. Rep., 239).

ISSUE:
Whether the plea of “guilty” entered by the accused, in light of his accompanying statements, constitutes a valid plea of guilt sufficient to sustain his conviction for the offense charged.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the accused. The Court ruled that the accused’s plea and statements did not amount to a plea of guilty to the offense charged. As established in United States vs. Labadan, the admitted facts (taking the oath while having unpaid taxes) were insufficient to sustain a conviction for the crime alleged. The trial judge should have ordered the substitution of a plea of “not guilty” for the plea of “guilty” entered in the record. The accused is acquitted, with costs de officio.