G.R. No. 6133 - People vs. Estavillo

The case involved sixteen persons charged in the Court of First Instance of Ilocos Norte for violating the Election Law by allegedly taking a false oath before the election board.
Two among them, Gregorio Julian and Francisco Agliam, were acquitted, while Gelacio Felipe was tried separately due to his absence during the initial proceedings.
The remaining fourteen defendants were tried together; after due consideration, the trial court found them guilty and, on January 12 and 14, 1910, imposed the following penalties:

A fine of P200 for each defendant.
Subsidiary imprisonment to be imposed at the rate of two pesos per day if the fine was not paid.
An order to pay one-sixteenth part of the costs.

The complaint charged that the defendants took a false oath on September 24, 1909, before the election board of the first electoral section of Laoag.
In the oath they swore that they were not delinquent in the payment of their land taxes for the year 1909 on properties located in various municipalities, including Laoag, Dingras, and Piddig.
It was alleged that by doing so, while knowing their actual delinquent status, their names were improperly registered in the voters’ list, thereby violating section 30 (specifically paragraphs 4 and 6) of the Election Law.

After the complaint was read, most defendants except for a few (including Gregorio Felipe, Urbano Agcaoili, Gregorio Julian, jr., and Francisco Agliam) interposed a demurrer, which was overruled by the trial court.
Subsequent answers by the defendants claimed that:

They did take the oath for the purpose of having their names inscribed in the electoral register.
They were not aware—due to absence, reliance on relatives, or other personal circumstances—that their land taxes were delinquent at the time they swore the oath.
Many testified that upon discovering their tax delinquency, they had promptly settled their arrears.

Detailed testimonies were rendered by the defendants (and some corroborative evidence provided by others) regarding:

Arrangements made for tax payments, including delegations to family members or other agents.
Periods of absence from their home municipalities, which contributed to their failure to secure the timely payment of taxes.
Specific circumstances such as illness or miscommunication that allegedly led to non-payment before taking the oath.

Paragraph 4 prescribed severe penalties for knowingly taking or subscribing to any false oath in election proceedings.
Paragraph 6 addressed the offense of causing one's name to be registered as a voter while knowing he is not qualified.

The complaint detailed not only the false oath itself but also the subsequent illegal registration which was intended to portray a complete criminal act.
The case also involved discussion on the collection of land taxes:

Act No. 1791 detailed the system for fixing the payment period, the procedures for notifying delinquent taxpayers, and the imposition of penalties for non-payment.
Act No. 1732 provided for subsidiary imprisonment in cases of failure to pay fines, specifying the mode of calculation and the rate (not less than two pesos per day, or two pesos and fifty centavos per day in case of insolvency).

The electors’ oath signed by each defendant on September 24, 1909.
Testimonies and documentary proofs relating to payment or non-payment of land taxes.

The prosecution contended that once a defendant is delinquent at the time of taking the oath, it must be presumed that he acted knowingly, regardless of subsequent remedial actions like paying taxes after swearing.

Whether the demurrer should have been sustained on the ground that the complaint charged more than one crime.

The issue focuses on whether the multiple allegations within the complaint amounted to separate offenses or merely detailed a single criminal act.

Whether it was incumbent upon the prosecution to prove that the notices prescribed in section 18 of Act No. 1791 had been given to each defendant before they could be considered delinquent.
Whether defendants are still guilty of violating the Election Law if they were delinquent at the time of taking the electors’ oath but later paid their taxes or did not vote.
Whether the prosecution must show that the defendants took the oath with actual knowledge of their tax delinquency, or whether such knowledge can be presumed.
Whether subsidiary imprisonment should be imposed according to the provisions of Act No. 1732, particularly in cases where the fine remains unpaid or partial payment leads to insolvency.