People v. Morandarte
REITERATIONFacts
The Antecedents: Pascual Morandarte took in Catalina and Santiago Siguenza, minors aged approximately 12 and 14, as house servants to pay off a debt left by their deceased father. The children disappeared from Morandarte's house, and he suspected they left with their brother, Eladio Siguenza, taking with them Morandarte's money and jewelry. Morandarte filed a theft complaint against Eladio Siguenza. Procedural History: In the preliminary investigation for theft, Victoriano San Antonio and Atanasia Mapa testified under oath that they saw Eladio Siguenza carrying a bundle containing money. Subsequently, they retracted their testimony, stating it was false and that they were induced by Pascual Morandarte to testify falsely. San Antonio and Mapa were prosecuted for perjury and sentenced by the Court of First Instance. During the perjury case, it was revealed that Morandarte induced them to bear false testimony. A complaint for subornation of perjury was filed against Morandarte, leading to his conviction by the Court of First Instance. The Appeal: Pascual Morandarte appealed his conviction for subornation of perjury, arguing against the evidence presented and the trial court's findings. The Supreme Court reviewed the evidence, including the testimony of the justice of the peace, other witnesses, and the conviction of San Antonio and Mapa for perjury, to determine Morandarte's guilt.
Issue(s)
Whether Pascual Morandarte is guilty of the crime of subornation of perjury under Act No. 1697. Whether the testimony of the perjured witnesses, San Antonio and Mapa, can be used to prove the subornation of perjury, despite their disqualification.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding Pascual Morandarte guilty of subornation of perjury. The penalty imposed was two years' imprisonment, a fine of P500, subsidiary imprisonment in case of insolvency, costs, perpetual disqualification from public office, and from testifying in court.
Ratio Decidendi
On Issue 1: The Supreme Court held that Pascual Morandarte is guilty of subornation of perjury. The Court found that Morandarte induced Victoriano San Antonio and Atanasia Mapa to testify falsely in the preliminary investigation for theft against the Siguenza brothers. The witnesses' subsequent retraction, stating they were induced by Morandarte to testify about seeing Eladio Siguenza carrying money and jewelry, established Morandarte's culpability. The Court emphasized that Morandarte, knowing the witnesses had no actual knowledge of the alleged theft, procured them to testify to an imagined act, thereby committing subornation of perjury as defined in Section 4 of Act No. 1697. On Issue 2: The Supreme Court ruled that the guilt of Pascual Morandarte for subornation of perjury was sufficiently proven, even though the witnesses San Antonio and Mapa were convicted of perjury and thus disqualified from testifying. The Court stated that the act of subornation itself was proven by other competent evidence. This included the testimony of the justice of the peace before whom the false declarations and subsequent retractions were made, the testimony of Sotero Buquiron who heard Morandarte instruct Atanasia Mapa, and the testimony of Silvina Morandante and Rosendo Alcantara, who testified to Morandarte's inducement and specific instructions to Victoriano San Antonio, including providing him with a memorandum of his testimony. Therefore, the conviction was based on evidence independent of the disqualified witnesses' testimony.
Main Doctrine
The crime of subornation of perjury, as defined in Act No. 1697, Section 4, is committed by any person who causes or procures another to commit perjury. The prosecution must prove that the accused induced, procured, or influenced another person to make a false statement under oath, knowing that such statement was false or that the witness had no knowledge of the facts they were testifying about. The conviction for subornation of perjury can be sustained even if the perjured witnesses are subsequently disqualified from testifying, provided there is sufficient independent evidence to prove the act of subornation.