G.R. No. 47684; June 10, 1941
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. DIONISIO A. MANEJA, defendant-appellee.

FACTS

The case involves the prosecution for the offense of false testimony. The appellee, Dionisio A. Maneja, gave his supposed false testimony in a basic criminal case (No. 1872) on December 16, 1933. The decision of the Court of Appeals in that basic case became final in December 1938. The lower court dismissed the case, holding that the prescriptive period for the offense (five years under Article 180, No. 4, in relation to Article 90 of the Revised Penal Code) commenced from the date the false testimony was given (December 16, 1933). The prosecution appealed, contending that the period should commence from the time the decision in the basic case became final (December 1938).

ISSUE

Whether the period of prescription for the offense of false testimony should commence from the date the false testimony was adduced or from the date the decision in the principal case became final.

RULING

The Supreme Court ruled in favor of the prosecution. The period of prescription commences from the day the crime is discovered by the offended party, the authorities, or their agents, pursuant to Article 91 of the Revised Penal Code. For the crime of false testimony, the penalties under Article 180 depend on whether the defendant in the principal case is convicted or acquitted. Therefore, the act of testifying falsely does not constitute an actionable offense until the principal case is finally decided. Before that final decision, the act cannot be discovered as a punishable offense. Computing the prescriptive period from the date the testimony is given would create an impossibility, as the length of the prescription period (which varies based on the penalty, which in turn depends on the outcome of the basic case) could not be determined until the basic case is resolved. The order of dismissal is reversed, and the case is remanded to the court of origin for further proceedings.