Title
People vs Gutierrez
Case
G.R. No. 4750
Decision Date
Jan 19, 1909
Gutierrez appealed a perjury conviction for false testimony in supplementary rent dispute proceedings; Supreme Court affirmed, reducing the fine.

Case Digest (G.R. No. L-51201)

Facts:

  • Background of the Case:
On January 30, 1908, Ricardo F. Gutierrez appealed a judgment from the Court of First Instance of Manila, which sentenced him to two months and one day of imprisonment, a fine of 6,250 pesetas, and payment of costs. The case originated from a dispute between Gutierrez and Vicente W. Pastor over unpaid rent and eviction.
  • Initial Proceedings:
On September 25, 1907, the justice of the peace court in Manila ordered Gutierrez to vacate the apartments he occupied and pay Pastor P35.33 for rent, P2 for legal costs, and P5.12 for proceedings costs. A writ of execution was issued, but it was returned unsatisfied on November 26, 1907.
  • Supplementary Proceedings:
Pastor initiated supplementary proceedings to enforce the judgment. The court summoned Gutierrez and his employer, The California-Manila Lumber Company, to produce account books and other evidence. Gutierrez appeared on December 11, 1907, and testified under oath that he had purchased two wardrobes for P45, which he later gave to a friend in Baliuag, Amalio Fernando, and shipped them by rail. He also claimed to have paid 30 centavos for transportation.
  • False Testimony Revealed:
Gutierrez later confessed that his sworn testimony was false. He admitted that the wardrobes were never sent to Baliuag and that he had fabricated the story on the advice of his employer’s attorney. This confession was corroborated by Machuca, who testified that Gutierrez had admitted to lying in court.
  • Conviction for Perjury:
Based on the false testimony and other evidence, Gutierrez was convicted of perjury and sentenced accordingly. He appealed, arguing that the judgment was contrary to law and evidence.

Issues:

  • Whether the false testimony given by Gutierrez in supplementary proceedings constitutes perjury under Article 321 of the Penal Code.
The defense argued that supplementary proceedings for execution are not a "civil cause" as defined by Article 321.
  • Whether Gutierrez knowingly gave false testimony.
The defense claimed that Gutierrez did not knowingly lie, but this argument was dismissed as it was not supported by the evidence or the law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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