People v. Maneja
REITERATIONFacts
The Antecedents: The appellee, Dionisio A. Maneja, allegedly adduced false testimony in criminal case No. 1872 on December 16, 1933. Procedural History: The lower court held that the period of prescription for the offense of false testimony commenced from the date the appellee adduced the supposed false testimony. The prosecution contended that the prescriptive period should commence from the time the decision of the Court of Appeals in the basic case became final in December, 1938. The Petition: The People of the Philippines appealed the lower court's decision dismissing the case.
Issue(s)
Whether the period of prescription for the offense of false testimony commences from the date the testimony was adduced or from the date the decision in the principal case becomes final.
Ruling
The order of dismissal is reversed, and the case is remanded to the court of origin for further proceedings, without costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the prescriptive period for false testimony commences only when the principal case is finally decided. Under Article 91 of the Revised Penal Code (RPC), prescription runs from the day the crime is discovered; however, the Court reasoned that a crime cannot be 'discovered' until it becomes an actionable and punishable offense. Since Article 180 of the RPC makes the penalties for false testimony dependent upon the conviction or acquittal of the defendant in the principal case, the specific legal character of the perjury remains undetermined until that case is resolved. For instance, if the accused in the main case is found guilty of murder, the perjurer faces 'reclusion temporal' (20-year prescription), but if the accused is acquitted, the perjurer faces only 'arresto mayor' (5-year prescription). Because the law bases the prescriptive period on the penalty, and the penalty is contingent on the final outcome of the main case, the actionability of the crime is suspended until finality. Applying the precedents of U.S. v. Opinion and People v. Marcos, the Court concluded that the prescriptive period must be computed from the date of final judgment in the basic case, which in this instance was December 1938.
Main Doctrine
The prescriptive period for the crime of false testimony commences not from the date the testimony was adduced, but from the date the decision in the principal case becomes final, as the offense is only actionable upon such final determination.