Case Digest (G.R. No. L-5290)
Facts:
The case involves the defendants Salustiano Pulido, Lazaro Pulido, and Antonio Pulido, who were accused of violating the Election Law by illegally taking certain election-related documents and ballot boxes from the office of the municipal secretary in Sanchez Mira, Cagayan. The events unfolded on November 5, 1907, during a general election where Felipe Navarro and Juan Academia were competing for the position of municipal president, while Mariano Acuna and Cosme Marzan vied for the vice-presidency. After the election, it was determined that Juan Academia and Cosme Marzan had won their respective positions. Following the counting of ballots, the board of inspectors delivered the sealed ballot boxes and other election materials to the municipal secretary, Liberato Lopez.
Due to a locked office, Lopez had to break in with the help of a policeman to secure the materials in a wardrobe, which he locked and took the key with him to his landlord's house. Later that night, whil...
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:
- 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.
- Credibility of Witnesses: The court found no reason to doubt the credibility of the witnesses, who positively identified the defendants as the perpetrators.
- Intent to Tamper: The torn seals on the ballot boxes indicated an intent to tamper with the election results, further supporting the conviction.
- 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.