GR L 2709; (December, 1905) (Digest)
G.R. No. L-2709
FACTS:
The defendant-appellant, Isidoro Aragon, was charged with the crime of false testimony (perjury) in a civil case. The charge stemmed from his testimony as a witness in a civil action for unpaid rent (Warner vs. Magcauas) before the justice of the peace court of Manila. During his examination, Aragon was asked a series of questions concerning his knowledge of the Pasay estate, its administrators, and previous ejectment suits involving its tenants during the period he served as an assistant justice of the peace in Singalong. To these questions, Aragon repeatedly answered that he did not know, did not remember, or had no recollection of the matters inquired about. The prosecution alleged these answers were absolutely false, asserting that Aragon, due to his former official position, had personal knowledge of and involvement in the matters referenced.
ISSUE:
Whether the evidence presented by the prosecution is sufficient to convict Isidoro Aragon of the crime of false testimony under Article 321 of the Penal Code.
RULING:
No. The Supreme Court reversed the judgment of conviction and ordered the case dismissed. To secure a conviction for false testimony in a civil case, the prosecution must prove: (1) the testimony was given in a civil cause; (2) it related to the issues presented; (3) it was false; (4) the defendant knew it was false; and (5) it was given maliciously with intent to affect the issues. The Court found the evidence insufficient, particularly on the third and fourth elements. The prosecution proved the existence of the underlying facts (e.g., the ejectment suits) but failed to prove that Aragon’s statements of lack of memory or recollection were themselves false. The mere fact that he had official dealings with those matters years prior did not establish that he was lying when he claimed, at the time of his testimony, that he could not remember them. Consequently, the prosecution did not meet its burden of proving beyond reasonable doubt that the appellant gave false testimony knowingly and maliciously.