Facts:

The case of The United States vs. Estanislao Gasingan pertains to a conviction of the defendant, Estanislao Gasingan, for perjury (falso testimonia). The initial proceedings commenced when Antonio Cabangis filed a case against Gasingan in the Court of First Instance of Manila, seeking to reclaim possession of a specific tract of land located in the barrio of Bancusay and the rents owed by Gasingan. The trial occurred around January 11, 1906, during which Gasingan testified in his defense. In his sworn statement, he asserted that Cabangis owned no land in Bancusay and stated that he had no leasing agreement, nor had he paid rent to Cabangis; he claimed to be occupying land owned by another individual, Enrique Barretto. However, in contrast to Gasingan's testimony, Cabangis and multiple witnesses testified that Cabangis was indeed the owner of the land in question and that Gasingan had been a tenant for a long period and had consistently paid rent. Furthermore, it was shown th

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Facts:

Criminal Charge and Trial

• The defendant, Estanislao Gasingan, was charged with the crime of falso testimonia (perjury).
• He was tried by the Court of First Instance of the City of Manila and found guilty.
• The sentence imposed included two months and five days of arresto mayor, the accessories of Article 61 of the Penal Code, a fine of 325 pesetas (or subsidiary imprisonment and payment if insolvent), and the costs incurred.

Background Civil Case Leading to the Incident

• Prior to January 11, 1906, Antonio Cabangis initiated an action in the same court seeking recovery of possession and rent from the defendant over a tract of land in the barrio of Bancusay.
• The civil case involved allegations by Cabangis that the defendant had been a tenant and had paid rent for a substantial period, reportedly fifteen to seventeen years.

Defendant’s Testimony in the Civil Case

• Estanislao Gasingan testified in his own behalf under oath that:
• Antonio Cabangis did not possess any land in the barrio of Bancusay.
• He was not occupying Cabangis’s land nor had he contracted or paid any rent to Cabangis.
• He was occupying a parcel of land belonging to Enrique Barretto.
• He had made no formal declaration with the city assessor and collector regarding the property in Bancusay.
• His testimony deliberately contradicted the evidence and testimony presented by Cabangis and other witnesses.

Contradictory Evidence Presented During the Civil Trial

• Multiple witnesses, including Cabangis and his wife, testified that:
• Cabangis owned land in the barrio of Bancusay.
• Gasingan had been a tenant for at least fifteen to seventeen years.
• Rent had been regularly paid to Cabangis.
• On December 26, 1903, the defendant had even executed a sworn declaration before Guy Schleigel, a clerk with the office of the assessor and collector, asserting ownership of the land in question.

Determination by the Court

• The record demonstrated that the defendant was not genuinely mistaken regarding the facts, particularly on matters of rent payment and his sworn declaration.
• The court found that Gasingan voluntarily, criminally, and corruptly testified falsely during the civil trial.
• The evidence of inconsistency in his testimony fully justified the imposition of the perjury charge.

Issue:

Whether the defendant, Estanislao Gasingan, committed perjury by intentionally providing false testimony during the civil trial in the Court of First Instance of Manila.

• The central issue concerned the genuineness of the defendant’s mistaken belief versus deliberate misconduct.
• It had to be determined if the discrepancies between his testimony and the submitted evidence were due to error or a willful falsification.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)