G.R. No. L-9869; March 25, 1915
THE UNITED STATES, plaintiff-appellant, vs. FEDERICO CAÑET, defendant-appellee.

FACTS:
The provincial fiscal of Iloilo filed an information charging Federico Cañet with the crime of perjury. The charge was based on an affidavit Cañet submitted as an integral part of a motion filed in the Court of First Instance of Iloilo. The motion sought the annulment of a judgment and the reopening of a civil case (Adraham Weill, as attorney for Levy Hermanos, vs. Federico Cañet). In the affidavit, Cañet made several assertions regarding a purported compromise agreement he claimed to have entered into with the plaintiff to settle the debt that was the subject of the suit, alleging that the plaintiff had agreed to dismiss the case and the accompanying attachment of his property. The information alleged these assertions were knowingly, willfully, and falsely made under oath before a notary public.

The defendant demurred to the information. The Court of First Instance of Iloilo sustained the demurrer and dismissed the case for lack of jurisdiction, evidently on the theory that the false statements in an affidavit, not made in open court or before a competent tribunal, did not constitute the crime of perjury. The government appealed this order.

ISSUE:
Whether the willful submission of a false affidavit, under oath, as evidence in a judicial proceeding constitutes the crime of perjury under the law then in force in the Philippines.

RULING:
Yes. The Supreme Court reversed the order of the lower court and held that the submission of false evidence in a judicial proceeding by means of an affidavit constitutes perjury.

The Court, citing authoritative definitions and its prior ruling in United States vs. Estraña, defined perjury as the willful and corrupt assertion of a falsehood under oath or affirmation administered by authority of law, in a material matter. The offense extends to false oaths taken in the course of judicial proceedings. The Court emphasized that a “willful assertion as to a matter of fact, opinion, belief, or knowledge made by a witness in a judicial proceeding as part of his evidence, either upon oath or in any form allowed by law to be substituted for an oath, whether such evidence is given in open court, or in an affidavit, or otherwise,” if known to be false and intended to mislead the court, constitutes perjury.

The Court rejected a narrow, technical interpretation that would limit perjury to testimony given in open court. It noted that the Code of Civil Procedure expressly allowed evidence to be given by affidavit in certain instances. To hold otherwise would create a dangerous loophole, allowing parties to submit deliberately false sworn statements from foreign jurisdictions with impunity, thereby opening the way to fraud and defeating the administration of justice. Public policy demands that the sanctity of the oath in all forms of judicial evidence be upheld to maintain faith in judicial proceedings.

Accordingly, the order sustaining the demurrer was set aside, and the case was remanded to the lower court for further proceedings. No costs were awarded.