Title
People vs Tria
Case
G.R. No. L-6013
Decision Date
Nov 15, 1910
Defendants in U.S. v. Tria convicted of illegal voting in the Philippines for failing to meet qualifications required by law and failing to present evidence to rebut presumption of guilt.
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Case Digest (G.R. No. L-6013)

Facts:

  • In "People vs. Tria," defendants, including Felipe Tria, were charged with violating the Election Law by voting in the November 2, 1909, general election without meeting legal qualifications.
  • Seventy-eight individuals were involved; fourteen were not tried, eight had their complaints dismissed, three were acquitted, and fifty-three were convicted and sentenced.
  • The appellants were accused of not holding specified offices before August 13, 1898, not owning real property worth at least 500 pesos or paying 30 pesos in taxes annually, and not being able to speak, read, and write English or Spanish.
  • The prosecution presented official registries and witness testimonies to prove the appellants did not meet the qualifications.
  • The defense did not present any evidence to counter the prosecution's claims.
  • The trial court reopened the case to recall a witness, which the appellants argued was prejudicial.
  • The trial court convicted the appellants, who then appealed the decision.

Issue:

  • (Unlock)

Ruling:

  1. The court ruled that the appellants did not meet the qualifications required by the Election Law to vote.
  2. The court found that the reopening of the case by the trial court to recall a witness was within its discretion and did not prejudice the appellants.
  3. The court held that it was not necessary to prove that the appellants kn...(Unlock)

Ratio:

  • The prosecution presented the best evidence obtainable, establishing a prima facie case against the appellants.
  • The burden of proof shifted to the appellants to rebut the prosecution's evidence, which they failed to do.
  • When the subject matter of a negative averment in a...continue reading

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