I've read a lot of warnings about cloaking and deceiving SE's and hidden text, etc. But what if I simply position a h1 heading to be -20 from the top so it's invisible, using css? Is this cloaking and would G penalize this u think? Would the robots even identify it as hidden? I've considered giving my css directory a different name and then disallowing that to robots, so the robots can't see it's hidden.
It's not an irrelevant heading anyway, but my site layout does not allow me to have my h1 heading with keywords near my body tag.