G.R. No. L-15132 - People vs. Cruz

On October 19, 1948, accused Rufo B. Cruz prepared and signed an application form (Philippine Civil Service Form No. 2) for the Civil Service Examination for Patrolman conducted by the Bureau of Civil Service.
The form was sworn before the municipal mayor of Cainta, Rizal, under oath.
Question No. 6 of the form asked if the applicant had ever been accused, indicted, or tried for any violation of law or regulation before any court. The accused answered “No”.

The accused was charged with wilfully making a false statement under oath in the Civil Service Form, stating that he had never been accused or tried for any crime.
In truth, the accused had been previously charged or indicted in three criminal cases before the Justice of the Peace Court of Cainta, Rizal:

Of these, Case No. 542 was forwarded to the Court of First Instance; the other two were dismissed for insufficiency of evidence.

The Court of First Instance of Rizal found the accused guilty of falsification of public document and sentenced him to an indeterminate penalty – from 4 months and 11 days of arresto mayor to 5 years, 6 months and 21 days of prision correccional, plus a fine and costs.
The accused appealed to the Court of Appeals, which certified the case to the Supreme Court due to purely legal questions involved.
The accused’s defense argued that the crime committed was perjury, not falsification, and that the offense had already prescribed by the time of prosecution.

Whether the offense committed by the accused in filling out the Civil Service application form was falsification of public document or perjury.
Whether the crime charged had already prescribed under Article 90 of the Revised Penal Code.
What is the proper penalty to be imposed on the accused.