G.R. No. 179441 - St. James College of Paranaque vs. Equitable PCI Bank

On September 21, 1909, the Court of First Instance of the subprovince of Masbate tried criminal case No. 163 titled “United States vs. Ana Ramirez.”
Ana Ramirez was charged with perjury for giving a false testimony in a homicide case involving Ciriaco Pellejera, who was accused of causing the death of her husband by blows.
In the homicide case, Ana Ramirez testified under oath that her husband died of fever without any contusions or injuries, contradicting earlier testimony she had given under oath before the provincial fiscal in Dimasalang.
The earlier testimony before the fiscal established that her husband died within three days after receiving blows from Ciriaco Pellejera, indicating a causal link between Pellejera’s actions and the death.

In the trial for perjury against Ana Ramirez, Estefania Barruga, her mother, testified regarding related matters which included an allegation that the fiscal, Señor Bailon, had attempted to rape Ana Ramirez and had proposed marriage to her.
This testimony by Estefania Barruga was given at the instigation of Leoncio Ballena, who would later be charged with subornation of perjury.
On September 29, 1909, following these events, the fiscal filed an information against Leoncio Ballena for inducing false testimony (subornation of perjury).

Leoncio Ballena was charged with subornation of perjury for allegedly inducing Estefania Barruga to testify falsely regarding the actions of the fiscal.
Ballena’s defense argued that the testimony given by Barruga was immaterial to the perjury case against Ana Ramirez, contending that it bore no relevance to the core issues of the case.
Despite his contentions, evidence established that Barruga’s false testimony was material to the inquiry into whether Ana Ramirez had previously testified that her husband died from the blows inflicted by Pellejera.

In both the perjury and the subornation of perjury cases, the prosecution was required to establish that all essential elements of the crimes were present, including the materiality of the testimony.
It was necessary to prove conclusively that:

The proceedings where perjury occurred were of a criminal nature and involved a duly constituted tribunal.
The witness, being duly sworn, gave false testimony that was material to the inquiry.
The defendant, Ballena, knowingly and willfully induced the witness to testify falsely for personal or other ulterior motives, such as an animosity towards the fiscal.

Whether the false testimony given by Estefania Barruga was material to the issues involved in the perjury case against Ana Ramirez.
Determination of whether the materiality of this testimony fulfilled one of the indispensable requisites for a conviction in a subornation of perjury case.

Whether Leoncio Ballena knowingly and willfully induced Estefania Barruga to give a false testimony.
Whether Ballena had sufficient awareness of the falsity of the testimony he procured, considering his personal vendetta against the fiscal.

Whether all essential elements of subornation of perjury—duly sworn testimony, materiality, and malicious inducement—were adequately established by competent evidence.
Whether the defense’s contention that the testimony was immaterial can override the evidentiary findings regarding the perjury and subornation.