People v. Torre
REITERATIONFacts
The Antecedents: On January 13, 1920, the prosecuting attorney of Ambos Camarines filed a complaint charging Pedro de la Torre with a violation of the Election Law. The complaint alleged that on April 25 or 26, or May 2 or 3, 1919, in Nabua, Ambos Camarines, the accused, Pedro de la Torre, willfully, feloniously, and unlawfully registered and caused his name to be registered in the list of voters for precinct No. 2 for the general election of June 3, 1919, despite knowing he lacked the qualifications of a voter. Procedural History: The defendant was arrested, arraigned, tried, found guilty, and sentenced by the Honorable Maximo Mina to six months imprisonment, a fine of P300, subsidiary imprisonment in case of insolvency, and costs. The defendant appealed the sentence. The Petition: The defendant appealed, alleging that the lower court erred in finding him guilty and in imposing the penalty.
Issue(s)
Whether the prosecution bears the burden of proving a defendant's inability to read and write when the defendant claims such literacy as a qualification for voter registration. Whether the mere act of making illegible marks on paper satisfies the legal requirement of being able to 'write' under the Election Law.
Ruling
The Supreme Court affirmed the decision of the lower court, finding the defendant guilty of violating the Election Law and upholding the imposed penalty.
Ratio Decidendi
On Issue 1: The Court ruled that the burden of proof rests on the defendant. Applying the principle from United States vs. Tria (17 Phil., 303), the Court held that where a negative averment in a complaint relates to a fact peculiarly within the defendant's knowledge or serves as a personal justification, the defendant must prove that fact. The ability to read and write is a personal attribute that the defendant is best positioned to demonstrate. Under the maxim 'Ei incumbit probatio qui dicit, non qui negat,' the defendant cannot remain silent and expect the prosecution to prove the negative of a fact that only the defendant can easily substantiate. Since De la Torre refused to provide proof of his literacy, he failed to overcome the evidence of his disqualification. On Issue 2: The Court determined that the defendant demonstrated by his own act that he could not write. The evidence showed that De la Torre signed his oath with such extreme difficulty that the resulting signature was entirely illegible. The Court clarified that the legal requirement to be able to 'write' means more than the physical capacity to make marks upon paper with a pen or pencil; it requires the ability to produce intelligible writing. Furthermore, the educational qualification is conjunctive; even if he could write, he was also required to be able to read. As there was no proof of his reading ability, and his writing was found deficient, he was properly convicted of illegal registration.
Main Doctrine
A person who registers to vote is presumed to know the law and the qualifications required for suffrage. The burden of proof rests upon the individual to demonstrate possession of these qualifications, especially when the justification or excuse for making the oath relates personally to them and lies peculiarly within their knowledge. Ignorance of the law or personal facts does not exempt one from criminal responsibility.