People v. Sarte
REITERATIONFacts
The Antecedents: A complaint was filed charging Martin Sarte with the crime of "false testimony" (perjury). The alleged perjury occurred during a civil action between Sarte and Valentin Sumayo concerning the sale of a carabao. Sarte falsely testified that he had not signed a certificate of sale for the carabao and had not received the purchase price of 150 pesos. Procedural History: The Court of First Instance of Ambos Camarines found Martin Sarte guilty of false testimony and sentenced him to four months and one day of imprisonment, a fine of 625 pesetas, and subsidiary imprisonment in case of insolvency. Sarte appealed this judgment. The Petition: The defendant appealed the decision of the lower court, challenging his conviction for false testimony.
Issue(s)
Whether a party to an action who gives false testimony as a witness in his own case can be convicted of the crime of "false testimony" under the provisions of General Orders, No. 58, and the Code of Civil Procedure. Whether the defendant, Martin Sarte, committed the crime of false testimony.
Ruling
The judgment appealed from is affirmed. The appellant shall pay the costs of the appeal and suffer subsidiary imprisonment in case of failure to pay the fine imposed.
Ratio Decidendi
On whether a party litigant can be convicted of false testimony: The Court held that under the provisions of General Orders, No. 58, and the Code of Civil Procedure, a party to an action who gives false testimony as a witness in his own case can be convicted of the crime of "false testimony." The Court reasoned that if a court can consider a party's sworn statement along with other evidence to decide a case, it is just that the party should be punished if their testimony is proven false, not as a party litigant but as a perjured witness. The Court emphasized that while a party might not be imprisoned for merely giving false testimony to please a litigant, the litigant themselves, who is the one truly interested in the outcome, should not benefit from their own criminal act of testifying falsely. The Court cited Spanish Supreme Court decisions from November 8, 1877, and June 9, 1882, which established that a party aggrieved by a crime who testifies as a witness is liable as such if their testimony is false. The Court concluded that it would be unjust to punish a witness who perjures themselves to favor a litigant, while allowing the litigant to benefit from their own false testimony. The Court also noted that Section 382 of the Code of Civil Procedure and Section 15, No. 3, of General Orders, No. 58, allow parties to an action to testify as witnesses without exclusion. On whether Martin Sarte committed false testimony: The Court found that it had been proven that the defendant, Martin Sarte, committed the crime of false testimony in the civil action. This was based on the evidence presented, including "Exhibit A," a certificate of sale, which was identified by witnesses Eugenio Elevado and Cecilio Vergara as having been signed by them at Sarte's request, and corroborated by the testimony of Valentin Sumayo. Sarte had denied selling the carabao, signing the document, or receiving the payment of 150 pesos, and had questioned the authenticity of his signature on the certificate. The Court considered the amount involved in the civil action and the extenuating circumstances under Article 11 of the Penal Code, imposing the minimum grade of the penalty prescribed in Article 321 of the Penal Code, without any aggravating circumstances.
Main Doctrine
A party to a civil action who gives false testimony as a witness in his own case can be convicted of the crime of false testimony (perjury) under Article 321 of the Penal Code, not as a party litigant but as a perjured witness.