Title
People vs Deloso
Case
G.R. No. 4411
Decision Date
Aug 31, 1908
Rufino Deloso was sentenced to four months of arresto mayor for falsifying a certificate of residence to vote in municipal elections.
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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

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