Title
People vs. Pulido
Case
G.R. No. L-5290
Decision Date
Jan 28, 1910
In a 1907 election, ballot boxes were stolen and tampered with; defendants were convicted of violating Election Law based on witness testimony and evidence of tampering.
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Case Digest (G.R. No. L-5290)

Facts:

Election and Initial Events:

  • On November 5, 1907, a general election was held in Sanchez Mira, Cagayan.
  • Felipe Navarro and Juan Academia were opposing candidates for municipal president, while Mariano Acuna and Cosme Marzan were opposing candidates for municipal vice-president.
  • After the polls closed, the board of inspectors counted the ballots and declared Juan Academia as president and Cosme Marzan as vice-president.

Handling of Ballot Boxes and Papers:

  • At around 8:00 PM, the inspectors delivered blank ballots, election papers, and locked ballot boxes containing the voted ballots to the municipal secretary, Liberato Lopez.
  • Lopez found his office locked, and after waiting for his clerk, he and policeman Antonio Pulido broke the lock to gain entry.
  • Lopez placed the papers and ballot boxes in a wardrobe, locked it, and took the key with him to Felipe Navarro’s house, where he was staying.
  • He instructed the chief of police to guard the office, as one of the door bars was broken.

Theft of Ballot Boxes:

  • Around 10:00 PM, Lazaro Pulido and Antonio Pulido arrived at Navarro’s house under the pretext of retrieving an empty demijohn.
  • Antonio entered Lopez’s room but left without the demijohn.
  • Later, Lopez discovered the wardrobe keys were missing and rushed to the municipal building, finding the wardrobe open and the ballot boxes gone.
  • A search was conducted, but the ballot boxes were not found.

Recovery of Ballot Boxes:

  • Lopez reported the incident to the justice of the peace and returned to the municipal building with officials.
  • Upon their return, they found the ballot boxes under a table in the secretary’s office, with torn seals and scattered papers.
  • The seals, bearing the initials of the board of inspectors’ president, were damaged, allowing ballots to be inserted despite the locks being intact.

Prosecution’s Evidence:

  • Witnesses Eustaquio Academia and Paulo Galicia testified that between 10:00 and 11:00 PM, they saw Salustiano Pulido, Lazaro Pulido, and Antonio Pulido carrying papers and ballot boxes near the municipal building.
  • When questioned, the defendants did not respond.

Election Protest:

  • Felipe Navarro, under the direction of Salustiano Pulido, protested the election.
  • The Court of First Instance of Cagayan declared the election null and void.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Sufficiency of Evidence: The prosecution’s evidence, including the testimony of witnesses and the circumstances surrounding the disappearance and recovery of the ballot boxes, sufficiently established the defendants’ guilt.
  2. Credibility of Witnesses: The court found no reason to doubt the credibility of the witnesses, who positively identified the defendants as the perpetrators.
  3. Intent to Tamper: The torn seals on the ballot boxes indicated an intent to tamper with the election results, further supporting the conviction.
  4. Judicial Discretion: The Supreme Court saw no reason to disturb the findings of the lower court, as the evidence clearly pointed to the defendants’ culpability.


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