Case Digest (G.R. No. L-2461)
Facts:
United States v. Martin Sarte, G.R. No. 2461, April 04, 1906, the Supreme Court, Torres, J., writing for the Court. The provincial fiscal of Ambos Camarines filed a complaint on December 2, 1904, charging Martin Sarte with the crime of false testimony (perjury) allegedly committed while testifying in a civil suit between Sarte and Valentin Sumayo. The complaint accused Sarte of falsely denying that he had signed a certificate evidencing the sale of a carabao and that he had received the purchase price.Following a hearing, the Court of First Instance rendered judgment on January 16, 1905, convicting Sarte and sentencing him to four months and one day imprisonment, imposing a fine of 625 pesetas, providing for subsidiary imprisonment in case of insolvency (not to exceed one-third of the principal penalty), and assessing costs. Sarte appealed that judgment to the Supreme Court.
At trial the prosecution introduced a written transfer, “Exhibit A,” dated July 3, 1901, purporting to memorialize the sale of a carabao by Sarte to Sumayo for 150 pesos and bearing the signatures of Sarte and two witnesses, Eugenio Elevado and Cecilio Vergara. In the civil proceeding Sarte testified that he did not recollect selling the carabao, denied signing the certificate, and denied receiving 150 pesos; he said he could only sign his name. Elevado and Vergara testified that they drew up and saw Sarte sign the document and that Sarte received the 150 pesos from Sumayo; their testimony was corroborated by Sumayo. Other witnesses (H. B. Waterman and George L. Armstrong) testified concerning Sarte’s testimony in the civil action.
The Supreme Court framed the central legal question as whether, under General Orders No. 58 and the Code of Civil Procedure, a party to an action who gives false testimony as a witness...(Pro-only)
Issues:
- Under General Orders No. 58 and the Code of Civil Procedure, can a party to an action who testifies in his own case and gives false testimony be convicted of the crime of false testimony (perjury) under Article 321 of the Penal Code?
- On the facts presented, was the conviction and the penalty imposed agai...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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