G.R. No. L-6294 / February 10, 1911
THE UNITED STATES, plaintiff-appellee, vs. LEONCIO BALLENA, defendant-appellant.

FACTS

Leoncio Ballena was charged with subornation of perjury. The charge stemmed from his alleged instigation of Estefania Barruga to give false testimony in the perjury trial of her daughter, Ana Ramirez. Ana had been convicted of perjury for falsely testifying in a homicide case that her husband died of fever, when she had previously testified under oath before the provincial fiscal that her husband died from blows inflicted by Ciriaco Pellejera. During Ana’s perjury trial, Estefania Barruga, at Ballena’s instigation, falsely testified that the fiscal had attempted to rape Ana and had asked for her hand in marriage. Ballena was subsequently tried and convicted for suborning this false testimony. On appeal, he contends that Barruga’s testimony was immaterial to the issues in Ana’s perjury case.

ISSUE

Was the false testimony given by Estefania Barruga in the perjury case against Ana Ramirez material to the issues of that case, such that Ballena can be validly convicted of subornation of perjury?

RULING

Yes. The Supreme Court affirmed Ballena’s conviction. The Court held that materiality is an essential element of both perjury and subornation of perjury. A “material matter” includes any circumstance that tends to prove the main fact in inquiry, corroborates testimony, or affects the credibility of a witness. In Ana’s perjury trial, the central issue was whether she had given contradictory sworn statements regarding the cause of her husband’s death. Barruga’s false testimonythat the fiscal attempted to rape Ana and proposed marriageif believed, would have severely discredited the fiscal, who was the complainant and a key witness against Ana. It would have portrayed the prosecution as malicious and fabricated, thus directly affecting the court’s assessment of the fiscal’s credibility and the merits of the case. Therefore, the testimony was material. Since all other elements of subornation were proven (Ballena knowingly and willfully procured the false testimony, and Barruga committed perjury), his conviction stands.