G.R. No. 9878 - People vs. Molina

On February 6, 1914, the prosecuting attorney of Ilocos Sur filed a complaint charging Frank Tupasi Molina with perjury.
The charge arose from an alleged false oath taken by Molina during his application for admission to the municipal police examinations.
The application was made in the municipality of Tayum, Ilocos Sur, and the examinations were held in Vigan on or about January 18, 1913.

The core of the complaint centered on Molina’s sworn statement in his examination petition signed on September 10, 1912.
In answering question No. 5 of the petition, which inquired if the applicant had ever been indicted, tried, or sentenced for any offense, Molina answered, “No, sir; I cannot remember any.”
This answer was deemed false given that evidence showed he had been indicted twice – once for disturbing the public peace and once for injurias graves – with corresponding convictions and fines.

Exhibit A: The sworn application petition wherein Molina answered the critical question using the name “Frank Tupasi y Molina” despite his known previous name, “Francisco Tupasi.”
Exhibits B, C, and D, which documented Molina’s criminal record:

Exhibit B: Arrest and conviction on February 20, 1911, for disturbing the public peace.
Exhibit C: Arrest and conviction on May 22, 1911, for injurias graves.
Exhibit D: A certificate from the Court of First Instance of Ilocos Sur reflecting a conviction for disturbing the public peace.

The application was sworn before a notary public, Lucas Magno, authorized to administer oaths.

Judge Francisco Santamaria found Molina guilty of perjury under Section 3 of Act No. 1697, having willfully signed an oath asserting a false statement.
The sentence imposed included:

Two months of imprisonment.
A fine of P100 (with subsidiary imprisonment in cases of insolvency).
Disqualification from holding public office or testifying in court until the sentence is reversed.
Payment of court costs.

Molina argued that the trial court erred in applying Section 3 of Act No. 1697 to his case.
He contended that there was no evidence that he had willfully or corruptly taken the oath.
He maintained that his construction of question No. 5 should have been favorably considered.
Molina disputed the equivalence of the phrase “which he does not believe to be true” in Act No. 1697 with the term “knowingly” as used in other statutes.
He ultimately sought acquittal on these grounds.

Whether the law, designed to punish perjury, is applicable in cases such as that of Molina’s application for a municipal police examination.
Whether the general provisions of the law extend to the regulation of examination applications conducted under executive authority.

Whether evidence sufficiently establishes that Molina took the oath willfully and with corrupt intent, despite his previous criminal record.
Whether the conduct in answering question No. 5 demonstrates a deliberate act to deceive the examining authorities.

Whether Molina’s understanding and subsequent response to question No. 5 was in line with the instructions provided in the application.
Whether his answer was a result of misunderstanding or an intentional misrepresentation.

Whether the phrase “which he does not believe to be true” in Section 3 of Act No. 1697 is equivalent to the term “knowingly” in similar perjury provisions.
The implications of this interpretation for establishing the requisite mens rea for perjury.

Whether the evidence presented (Exhibits A, B, C, and D) adequately demonstrated Molina’s criminal background, thereby impeaching his sworn declaration.
The impact of Molina’s use of the name “Frank” versus “Francisco” on the credibility of his sworn statement.