Case Digest (G.R. No. 4411)
Facts:
- Rufino Deloso aimed to participate in the municipal elections on December 1, 1904, in Jimenez, Misamis.
- He declared under oath to the municipal secretary that he was a resident of Jimenez and would meet the six-month residency requirement by election day.
- On December 5, 1905, Deloso was elected as the municipal president of Oroquieta, a nearby town.
- His election was contested by residents of Jimenez, who argued he did not legally reside there.
- Deloso reiterated his residency in Oroquieta under oath on January 4, 1906, before a notary public.
- Evidence included two documents signed by Deloso confirming his residence in Oroquieta and stating he had never voted in Jimenez.
- The provincial fiscal filed a complaint against Deloso for falsification of official documents.
- The lower court found him guilty under Article 311 of the Penal Code, sentencing him to four months of arresto mayor, along with accessory penalties and costs.
- Deloso appealed the judgment.
Issue:
- (Unlock)
Ruling:
- The court ruled that Rufino Deloso committed the crime of falsification of official documents by knowingly making false declarations about his residency.
- The court held that ignorance of the law ...(Unlock)
Ratio:
- The court's decision was based on clear evidence that Deloso knowingly provided false information regarding his residency to the municipal secretary of Jimenez.
- Documents presented during the trial, including a notarial declaration, confirmed his residence in Oroquieta and indicated he had never lived in Jimenez.
- The court emphasized that falsifying a certificate, even by a private individual, constitutes a crime under the Penal Code.
- Deloso's claim of ignoran...continue reading
Case Digest (G.R. No. 4411)
Facts:
The case involves Rufino Deloso, who sought to participate in the municipal elections scheduled for December 1, 1904, in Jimenez, Misamis. To qualify as a voter, Deloso visited the municipal building and, under oath, declared to the municipal secretary that he was a resident of Jimenez and would have resided there for six months by the time of the elections. Subsequently, on December 5, 1905, he was elected as the municipal president of Oroquieta, a nearby town, by a majority vote. However, his election was contested by several residents of Jimenez, who claimed that he did not legally reside there. In his defense, Deloso reiterated under oath on January 4, 1906, before a notary public, that he had been a resident of Oroquieta since April 1902. Evidence presented during the trial included two documents signed by Deloso, which confirmed his residence in Oroquieta and indicated that he had never voted in Jimenez. The provincial fiscal subsequently filed a complaint against Deloso for falsification of official documents. The lower court found him guilty under Article 311 of the Penal Code, sentencing him to four months of arresto mayor, along with accessory p...