G.R. No. L-9030; October 16, 1914
THE UNITED STATES, plaintiff-appellee, vs. PEDRO ROSALES, ET AL., defendants-appellants.

FACTS:
The defendants-appellants, Pedro Rosales, Feliciano C. Veloria, and Florentino Buquingo, were convicted by the Court of First Instance of Surigao for violating paragraph 4, section 30 of the Election Law. They were charged with having taken a false oath by swearing they were not delinquent in the payment of taxes when they registered to vote in the general election of May 4, 1912. The municipal treasurer’s certifications (Exhibits E, F, and H) established that all three were delinquent in paying their land tax for the year 1911 as of the election date, and they only made payments in June 1912. In their defense, each appellant claimed they had sold the land subject to the tax prior to the election (Rosales in 1910, Veloria in 1911, and Buquingo also by sale), and therefore believed they were no longer liable for the tax.

ISSUE:
Whether the appellants are guilty of violating the Election Law by taking a false oath regarding their tax delinquency, despite their claim of having sold the taxed property before the election.

RULING:
Yes, the appellants are guilty. The Supreme Court affirmed the lower court’s judgment. The Court held that the fact of their tax delinquency on the election date (May 4, 1912) was established by the treasurer’s certifications showing payment was made only after May. The appellants’ defense that they sold the land did not negate their delinquency, as the tax remained unpaid as of the crucial date. The Court further ruled that the element of knowingly making a false statement is presumed from the voluntary act of taking the oath, in accordance with a prior doctrine (17 Phil. Rep., 303). The appellants failed to present sufficient evidence to rebut this presumption. The penalty imposed by the trial court was sustained.