G.R. No. L-22944 - People vs. San Juan

Case Summary (G.R. No. L-22944)

Facts and Charges

The indictment accused Claudia San Juan and Severo San Juan of conspiring and using force to prevent Generosa Pilapil, the complaining witness, from freely entering the polling place to vote. The information alleged that the defendants willfully and feloniously obstructed her right to enter freely. The Court of First Instance dismissed the case, holding that the facts charged did not constitute an offense based on precedent in U.S. vs. Pompeya.

Legal Issue: Sufficiency of the Information and Exception in Section 133

The only question on appeal was whether the indictment sufficiently alleged all essential elements of the offense under Section 133 of the Revised Election Code. Section 133 grants voters the right to vote in order of entrance and to freely enter the polling place unless "there are more than forty voters waiting inside," in which case entry must follow order of arrival as others exit. The prosecution's information did not explicitly exclude the exception of more than forty voters waiting inside.

Jurisprudential Principle on Exceptions in Criminal Statutes

The Court cited established jurisprudence, notably U.S. vs. Chan Toco and People vs. Cadabis, that exceptions in a statute do not form part of the crime's essential elements and are not required to be negated by the prosecution in the information. Instead, once an offense is charged, the burden is on the accused to allege and prove any claimed exception or defense. This principle has been consistently applied in cases involving statutory exceptions, such as exemptions for licensed physicians under the Opium Law or public officers carrying deadly weapons in polling places.

Distinction from U.S. vs. Pompeya

The ruling acknowledged that in U.S. vs. Pompeya, a different principle applied where the ordinance regulated specific classes under special conditions, and the complaint had to affirmatively show the defendant's liability by negating exemptions. However, Section 133 defines the offense generally without limiting application to particular classes or special conditions. The exception regarding more than forty voters inside the polling place is separable, and not negating this clause does not vitiate the legal sufficiency of the information.

Importance of the Right of Suffrage

The Court emphasized the fundamental nature of the right to vote as the bedrock of republican government and democratic institutions. It underscored the need to protect the voter's free exercise of suffrage against any unlawful impediment, recognizing the critical constitutional value of unmolested access to the polling place. Any unauthorized obstruction or use of force impinging on this right is regarded as a grave offense impacting the democratic process.

Conclusion and Final Holding

The Court held that the information as filed sufficiently charged an offense under Section 133 of the Revised Election Code. The limitation clause regarding more than forty voters was not an essential element that the prosecution needed to negate. Instead, it was for the defend

Case Syllabus (G.R. No. L-22944)

Background and Procedural History

The case involves an appeal by the People of the Philippines from an order dated April 17, 1964, issued by the Court of First Instance of Leyte, Ormoc City.
The trial court quashed the indictment against Claudia San Juan and Severo San Juan for violation of Section 133 of the Revised Election Code.
The accused were charged with willfully, unlawfully, and feloniously using force to prevent the complainant, Generosa Pilapil, from freely entering a polling place during the election on November 12, 1963, in Ormoc City.
The Court of First Instance dismissed the case on the ground that the facts charged did not constitute an offense, relying on the rule established in U.S. vs. Pompeya.
The Supreme Court was tasked to review whether the indictment sufficiently alleged all essential elements of the offense.

Legal Issue and Scope of Inquiry

The sole legal question was whether the information sufficiently set forth the essential elements constituting the offense under Section 133 of the Revised Election Code.
The appeal focused on the legal sufficiency of the indictment, particularly regarding the explicit negation of statutory exceptions related to a voter’s right to enter the polling place.
The inquiry was confined to the allegations of the information, which, because of the motion to quash, were assumed admitted by the defense for purposes of legal sufficiency.

Statutory Provision and Right Invoked

Section 133 of the Revised Election Code guarantees the right of voters to vote in the order of their entrance into the polling place and to freely enter the polling place as soon as they arrive, subject to an exception.
The exception applies when there are more than forty voters inside, allowing entering only in order of arrival as those inside leave.
The information alleged unlawful prevention of the complainant from exercising the right to freely access the polling place.
The indictment did not negate the exception clause concerning the more than forty voters waiting inside.

Jurisprudential Principles on Exceptions in Criminal Charges

The Supreme Court