GR L 2461; (April, 1906) (Digest)
G.R. No. L-2461
FACTS:
The defendant-appellant, Martin Sarte, was charged with the crime of false testimony (perjury). The charge stemmed from a civil action between Sarte and Valentin Sumayo regarding the sale of a carabao. In his testimony during that civil case, Sarte falsely denied having signed a certificate of sale for the carabao and having received the purchase price of 150 pesos from Sumayo. Evidence presented during the criminal trial for perjury, including the certificate of sale (“Exhibit A”) and the testimonies of the subscribing witnesses and Sumayo, established that Sarte had indeed executed the document and received the money. The Court of First Instance convicted Sarte and sentenced him to imprisonment and a fine. Sarte appealed the conviction.
ISSUE:
Whether a party to a civil action who gives false testimony as a witness in his own behalf can be convicted of the crime of false testimony (perjury) under the prevailing procedural laws (General Orders No. 58 and the Code of Civil Procedure).
RULING:
Yes. The Supreme Court affirmed the conviction. The Court held that under the then-prevailing procedural laws, parties to an action were not excluded from being witnesses and were entitled to testify in their own behalf. Consequently, when a party litigant takes the stand and gives testimony, he assumes the role and obligations of a witness. If such testimony is proven to be false, the party can be held criminally liable for perjury not as a litigant, but specifically as a false witness. The Court found this rule necessary for the protection of the public and the moral interests of the community, as it would be unjust to allow a litigant to benefit from his own criminal act of giving false testimony while punishing other witnesses who might have perjured themselves on the litigant’s behalf. The Court cited supporting doctrine from the Supreme Court of Spain. Upon the evidence, the Court found that Sarte’s guilt for false testimony was proven beyond reasonable doubt. The penalty imposed by the lower court was affirmed.