G.R. No. 5751 - People vs. Estrana

The case involves the United States as plaintiff and Lope Estrana as defendant and appellant.
The criminal case at issue, No. 1055, pertained to the murder of a Roman Catholic priest in Escalante, Negros Occidental.
Estrana was called to testify in that murder case as a witness for the defense.

On May 15, 1909, Estrana testified under oath that he resided in the barrio of Japitan and that at about 7 p.m. that evening, Dionisio Tambolero came to his house.
Estrana claimed that Tambolero remained at his house throughout the night until about 5 a.m. on May 16, 1909.
The testimony was given in the context of criminal case No. 1055, wherein details about the events surrounding the priest’s assassination were under investigation.

Dionisio Tambolero’s own testimony contradicted Estrana’s account, as he stated that he was in Escalante on the evening of May 15, 1909.

Tambolero’s detailed timeline included attending mass, visiting the sacristia at around 4 p.m., stopping by a store, and spending the night at another house rather than Estrana’s.
He attested that he was at the convent a few minutes after 5 a.m. on May 16, 1909, to assist with the preparation of the deceased priest’s body.

Testimonies from other witnesses such as Natalio Inson, Gregorio Tudanca, Celedonia Samonte, and Vicente Olmedo corroborated Tambolero’s account.
Given the considerable distance between Estrana’s house in Japitan and the town of Escalante, it was physically implausible for Tambolero to have left Estrana’s house at the time claimed and thereafter reach the convent in time.

The prosecuting officers charged Estrana with perjury, alleging that his testimony in the murder case was false.
The charge was based on his having testified that Tambolero had passed the night in Estrana’s house, contrary to the factual timeline established by Tambolero’s own and corroborating testimonies.

Counsel for the appellant contended that the complaint did not adequately allege that Estrana’s testimony was material to the issues in the murder case.
The appellant’s counsel also argued that under Act No. 1697, perjury does not require multiple contradictory testimonies but must involve a false assertion that is material to the case.
An assertion made by appellant’s counsel on appeal noted (though without competent corroboration) that Tambolero might have testified in the murder trial as having seen one of the defendants with a bolo—an observation introduced solely in the appellate brief and not verified in open court.

Whether Estrana’s testimony constitutes perjury under Section 3 of Act No. 1697.

Does his single, allegedly false statement—asserting that Tambolero spent the night at his house—meet the statutory elements of perjury?
Is the false testimony actionable as perjury even without a second, contradictory testimony?

Whether the false testimony was material to the issues involved in the murder case (criminal case No. 1055).

Is proving the materiality of the false statement essential for a perjury conviction under Act No. 1697?
Does the record sufficiently demonstrate that Estrana’s false testimony was central to the prosecution’s case against him?

The admissibility and sufficiency of appellate evidence regarding Tambolero’s remarks in the murder trial.

Can the statement made by counsel in the appellate brief—which referenced Tambolero’s alleged testimony regarding another defendant—be considered competent proof of materiality?
Is such late evidence admissible to overcome the deficiencies in the original perjury complaint?