People v. Chanco
REITERATIONFacts
The Antecedents: Five separate complaints were filed against Gervasia Go Chanco, Aniceta Reyes, Carlos Ortiz, Marta Sumera (alias Silvestra Rivera), and Mariano Gabriel for the crime of perjury. The cases were consolidated and tried together. The defendants were found guilty and sentenced to imprisonment, a fine, and disqualification from holding public office or testifying in court. Procedural History: The defendants were found guilty by the Court of First Instance of Manila and sentenced accordingly. They appealed the decision to the Supreme Court. The Petition: The defendants assigned three errors: (I) overruling the demurrer to the complaints, (II) holding that the board of special inquiry was a competent tribunal, and (III) holding that the accused were guilty beyond a reasonable doubt.
Issue(s)
Whether the complaints sufficiently stated the offense of perjury. Whether the board of special inquiry constituted a competent tribunal to administer the oath. Whether the guilt of the accused was proven beyond a reasonable doubt.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding all the defendants guilty of perjury. The sentence of imprisonment, fine, and disqualification was upheld.
Ratio Decidendi
On Issue 1: The Court held that the complaints were sufficient. It reiterated the doctrine that a complaint is sufficient if it states the facts in a manner that enables a person of common understanding to know what is intended and the court to pronounce judgment according to right. For perjury, this includes alleging the substance of the controversy, the officer administering the oath, the authority to administer it, the falsity of the oath, and the assignment of perjury. The complaints, by describing the offense in the language of the statute (Section 3 of Act No. 1697) and providing specific details of the false testimony, met these requirements. On Issue 2: The Court ruled that the board of special inquiry was a competent tribunal. It cited previous decisions establishing that the customs department is charged with inquiring into and deciding the right of Chinese to enter the Philippines. Section 21 of Act No. 355 empowers members of such boards to administer oaths when authorized by the Collector of Customs. The record showed that the members were duly appointed and authorized. Therefore, the board constituted a tribunal in a case where Philippine laws authorized an oath to be administered, making the false testimony given before it constitute perjury. On Issue 3: The Court found that the guilt of the accused was proven beyond a reasonable doubt. The evidence demonstrated that Marta Sumera falsely claimed to be the mother of three Chinese boys seeking entry, stating they were born and baptized in Manila. The other defendants corroborated her false testimony. Crucially, the real Silvestra Rivera, the actual mother of three boys of the same names and ages, who were born and baptized in Manila, appeared and testified, proving the falsity of the defendants' declarations. The baptismal certificates presented by the defendants were for the real sons of the real Silvestra Rivera, further highlighting the falsity of the defendants' oaths.
Main Doctrine
A complaint for perjury is sufficient if it alleges facts constituting the offense in plain and intelligible terms, with sufficient certainty to apprise the accused of the charge, and specifies the substance of the controversy, the officer administering the oath, the authority to administer it, the falsity of the oath, and the assignment of perjury. A board of special inquiry, authorized to investigate the right of aliens to enter the Philippines and to administer oaths, constitutes a competent tribunal for the purpose of perjury.