G.R. No. L-10550, December 3, 1915
THE UNITED STATES, plaintiff-appellee, vs. JUANA DE LOS SANTOS, defendant-appellant.

FACTS:
Juana de los Santos was convicted of perjury by the trial court and sentenced to three months imprisonment and a fine of P100. The conviction arose from the following events: The accused, a poor and ignorant woman who had recently given birth, filed a sworn complaint before a justice of the peace charging her husband with assault, battery, and criminal threats. She alleged under oath that he had maltreated her, kicked her violently, and threatened her with a knife. However, when the case was called for trial a week later, she attempted to withdraw her complaint and declared under oath that her husband had never maltreated her and that it was not true he had threatened her with a knife. It was established that she had, in fact, been maltreated by her husband.

ISSUE:
Whether the penalty imposed by the trial court for the crime of perjury is appropriate under the attendant circumstances of the case.

RULING:
The Supreme Court affirmed the conviction but modified the penalty. The Court held that the guilt of the accused for the crime of perjury was conclusively established, as she knowingly made a false statement under oath. However, the Court emphasized that the penalty for perjury (imprisonment of up to five years and a fine of up to P2,000) grants the courts wide discretion to consider all attendant circumstances.

The Court found the circumstances justified a penalty near the minimum. The accused was a wretched, ignorant woman who had recently given birth and had actually been a victim of her husband’s maltreatment. Her false testimony at the trial was not given with malice or for personal gain, but in a misguided effort to shield her husband from punishment and to forgive him, after having initially sought justice when the offense was fresh. The Court distinguished this act from more egregious forms of perjury, such as falsely swearing away another’s life or liberty or testifying falsely for personal civil gain.

Consequently, the Supreme Court modified the sentence to five days of imprisonment and a fine of P5, affirming the conviction as thus modified.