G.R. No. L-9348; March 14, 1914
THE UNITED STATES, plaintiff-appellee, vs. ELEUTERIO MANTE, defendant-appellant.

FACTS:
Eleuterio Mante was convicted in the lower court for violating the Election Law by taking the oath of office as a municipal councilor and discharging its duties while knowing he was disqualified due to delinquency in the payment of his taxes. The prosecution established a prima facie case by presenting Mante’s oath of office, minutes showing his participation in a council session, and an official tax receipt dated after those events, proving his tax delinquency at the time he assumed office.

In his defense, Mante testified that he believed his taxes had been paid. He claimed that on the Friday before his Saturday oath-taking, he gave money and his previous year’s tax receipt to his two adult sons to pay his taxes in town. The elder son, who carried the money, became intoxicated and failed to pay. Upon returning home, the younger son, relying on his brother’s false assurance, told their father the taxes had been paid. Mante, relying on this information, took his oath on Saturday. The elder son confessed the non-payment on Sunday, and Mante paid the tax the following Monday. The trial court discredited this testimony solely because the witnesses were related and interested in Mante’s acquittal.

ISSUE:
Whether the prosecution proved beyond a reasonable doubt that Eleuterio Mante took his oath of office knowing he was delinquent in his tax payments.

RULING:
NO. The Supreme Court acquitted Eleuterio Mante.

The Court reiterated the doctrine from U.S. vs. Tabuyo that while proof of tax delinquency and the subsequent exercise of official duties creates a prima facie case of knowledge, this presumption is rebuttable. The accused must only raise a reasonable doubt as to his knowledge. The defense of lack of knowledge must be reasonable and adequate; it fails if the accused voluntarily ignored the truth or negligently failed to inquire.

In this case, the Court found Mante’s defense reasonable and credible. His actions showed a bona fide belief that his taxes had been paid: he entrusted the payment to his adult sons with sufficient funds before his qualification, and he promptly paid upon learning of the error. The trial court erred in rejecting the testimony of the defense witnesses based solely on their relationship to the accused. When such testimony is reasonable, consistent, and uncontradicted by reliable evidence, it should be credited.

Mante’s conducthis awareness of the law’s penalty, his attempt to pay beforehand, and his immediate payment upon discovery of the mistakenegated the inference of criminal knowledge. The facts and applicable law were held to be analogous to U.S. vs. Lopez. Consequently, the prima facie case was successfully rebutted, and Mante was acquitted with costs de oficio.