United States v. Palma

Summary

Santos P. Palma was convicted of perjury under the Election Law for taking a false oath during voter registration. He had purchased land in 1908-1909 but deliberately failed to declare it for taxation until 1910, avoiding tax payments for three years. When he took the elector's oath in April 1912, he falsely declared he was not delinquent in tax payments. The Supreme Court affirmed his conviction, establishing the principle that property owners who willfully avoid declaring their property to evade taxation are considered delinquent even without formal assessment, and are guilty of perjury if they take contrary oaths. This case clarifies the relationship between tax obligations, election law requirements, and criminal liability for false oaths in the early American colonial period of Philippine jurisprudence.