GR L 5210; (December, 1909) (Digest)
G.R. No. L-5210
THE UNITED STATES, plaintiff-appellee, vs. VALERIA DE CHAVES, defendant-appellant.
December 4, 1909
FACTS::
On November 2, 1908, Valeria de Chaves, unable to speak Spanish, testified under oath before the provincial fiscal of Batangas regarding a robbery committed in her house on February 27, 1908. Her testimony, translated into Spanish by the fiscal, stated that she personally saw Marcelo Remo, Ciriaco Josaeta, and Aniceto Aguila steal a trunk and that she did not resist because one of them threatened her with a bolo.
However, during the trial of the robbery case on January 5, 1909, Valeria de Chaves testified that she did not see any of the accused commit the robbery. Instead, she stated that her 6 to 7-year-old daughter awoke her and informed her that the three accused had stolen the trunk and that one of them had threatened the daughter.
Due to this contradiction, the provincial fiscal filed a complaint against Valeria de Chaves for perjury under Section 3 of Act No. 1697. The trial court found her guilty and sentenced her to one year imprisonment and a fine of P100. Valeria de Chaves appealed. It was established that the robbery itself did occur, and the stolen items were not recovered.
ISSUE::
Whether Valeria de Chaves committed the crime of perjury as defined by Act No. 1697, given the contradiction between her initial sworn statement and her later testimony in court.
RULING::
The Supreme Court reversed the lower court’s judgment and acquitted Valeria de Chaves.
The Court held that for perjury to exist, the false statement must be made “willfully and contrary to such oath” concerning a material matter which the person “does not believe to be true.” While there was a contradiction in Valeria de Chaves’ statements, there was no satisfactory proof that she knowingly and intentionally testified falsely.
The Court reasoned that:
1. Valeria de Chaves consistently maintained that a robbery had occurred, which was a truthful and unconvertible fact. The contradiction pertained only to how she acquired knowledge of the robbery (whether she saw it herself or was informed by her daughter).
2. Given her inability to speak Spanish, it was highly probable that the discrepancy in her initial statement before the fiscal was due to error, misunderstanding of questions, or mistranslation.
3. Her insistent affirmation in court that her daughter informed her, not that she witnessed it herself, suggested that this was her true and conscientious belief. There was no apparent motive for her to intentionally change her testimony.
4. A mere contradiction, especially concerning details rather than the principal fact of the crime, without proof of intent to pervert the truth, is insufficient to establish perjury. In cases of doubt, it is proper to assume that the truth was stated before the trial court and that any error or mistake occurred during the earlier testimony to the fiscal.
Thus, lacking proof of willful intent to commit perjury, Valeria de Chaves could not be found guilty.
