People v. Cañet
REITERATIONFacts
The Antecedents: Federico Cañet presented an affidavit to the Court of First Instance of Iloilo, seeking the annulment of a judgment rendered in a civil suit. The affidavit contained statements that the prosecution alleged were false and made knowingly, willfully, intentionally, criminally, and falsely under oath before a notary public in Manila. Procedural History: The provincial fiscal of Iloilo filed an information for perjury against Federico Cañet. The defendant demurred to the amended information, raising two grounds: (1) the facts alleged do not constitute the crime charged, and (2) the crime was not committed within the court's jurisdiction. The lower court overruled the demurrer on the first ground but sustained it on the second, dismissing the case for lack of jurisdiction. The Petition: The United States appealed the dismissal order, arguing that the lower court erred in dismissing the case for lack of jurisdiction.
Issue(s)
Whether the Court of First Instance of Iloilo has jurisdiction over a perjury charge when the underlying false affidavit was subscribed and sworn to in Manila but presented as evidence in a judicial proceeding pending in Iloilo.
Ruling
The Supreme Court reversed the order of dismissal, holding that the lower court erred in dismissing the case for lack of jurisdiction. The Court ruled that the crime of perjury was committed within the jurisdiction of the Court of First Instance of Iloilo because the defendant, by means of the false affidavit, "swore to" and knowingly submitted false evidence material to a point at issue in a judicial proceeding pending in that court. The location where the affidavit was subscribed and sworn to is immaterial.
Ratio Decidendi
On Issue 1: The Supreme Court held that the gist of the offense is not the act of making the affidavit in Manila, but the intentional giving of false evidence in the Court of First Instance of Iloilo by means of such affidavit. The Court emphasized that it is immaterial where the affidavit was subscribed and sworn as long as it was 'sworn to' and knowingly submitted to a court in a pending judicial proceeding to mislead that court on a material issue. Relying on United States v. Estraña, the Court defined perjury under Section 3 of Act No. 1697 as the willful and corrupt assertion of a falsehood under oath for the purpose of influencing the course of law. The Court reasoned that any other interpretation would lead to a failure of justice, as parties could go to foreign countries or different provinces to swear false affidavits and then use them to commit fraud in Philippine courts with absolute impunity. The Court noted that the Code of Civil Procedure specifically allows evidence to be given via affidavit, and these affidavits may even be taken in foreign countries, making it essential for the court where the proceeding is pending to have the power to punish perjury. Consequently, the act of presenting the false affidavit in Iloilo to secure a favorable decision in a civil suit constitutes the commission of perjury within that jurisdiction.
Main Doctrine
It is perjury in the Philippine jurisdiction to submit false evidence in a judicial proceeding by means of an affidavit, even if the affidavit was subscribed and sworn to outside the territorial jurisdiction of the court where the judicial proceeding is pending.