Title
People vs. Matan
Case
G.R. No. L-14129
Decision Date
Jul 31, 1962
Justice of the peace charged under election law; Supreme Court ruled "judge" in Section 54 includes justices of the peace, remanding case for trial.

Case Digest (G.R. No. L-14129)
Expanded Legal Reasoning Model

Facts:

  • Procedural History
  • The Provincial Fiscal of Pangasinan filed an information in the Court of First Instance charging Guillermo Manantan with violating Section 54 of the Revised Election Code.
  • A preliminary investigation found probable cause. At trial, Manantan pleaded not guilty and filed two motions to dismiss:
    • First motion: Argued that, as a justice of the peace, he was not among the officers enumerated in Section 54.
    • Second motion: Relied on People v. Macaraeg (C.A. No. 15613-R), where the Court of Appeals held that a justice of the peace is excluded from Section 54.
  • Lower Court Disposition
  • The trial court denied the first motion, holding that a justice of the peace falls within Section 54’s prohibition.
  • On the second motion, after submissions by both parties, the court dismissed the information against Manantan, following People v. Macaraeg.
  • Supreme Court Appeal
  • The Solicitor General appealed to the Supreme Court.
  • The sole question presented: Is a justice of the peace included in the prohibition of Section 54 of the Revised Election Code?

Issues:

  • Primary Issue
  • Whether a justice of the peace is included among the officers prohibited by Section 54 of the Revised Election Code from aiding any candidate, exerting influence in an election, or taking part therein (except to vote or preserve public peace).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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