Case Summary (G.R. No. 173935-38)
Factual Background
Respondents, as purported LDC corporate officers, filed sworn petitions alleging that original titles over condominium and real property were lost despite “earnest and diligent efforts” to locate them. Petitioner, asserting rightful possession of those originals, opposed the petitions. Respondents amended their pleadings to recite the belief of loss and to justify non-possession. Based on the original petitions, petitioner filed perjury charges before the Pasig City Prosecutor, alleging that those statements were willfully false and made to obtain new duplicate titles to petitioner’s prejudice.
Proceedings in the MeTC and RTC
- Pasig City Metropolitan Trial Court (MeTC), Branch 72: Quashed the four consolidated informations for perjury on the ground that statements in judicial pleadings are absolutely privileged and hence not criminally prosecutable.
- Pasig City RTC, Branch 263: Denied petitioner’s motion for reconsideration and affirmed the MeTC decision.
Supreme Court Certiorari Petition
Petitioner sought review under Rule 45, raising purely questions of law, contending that:
- Statements in pleadings, even if false, are not absolutely privileged against perjury charges; and
- The MeTC and RTC misapplied precedents (Flordelis v. Himalalaon and People v. Aquino) concerning privilege in pleadings.
Supreme Court’s Jurisdictional Analysis
The Court first addressed venue, a jurisdictional requirement in criminal prosecutions. Although the informations alleged that the petitions were “subscribed and sworn” in Pasig, they failed to specify that the material Judicial Proceedings occurred in Makati and Tagaytay—where the petitions were actually filed and where the alleged falsehoods had material effect. Under Article 183 RPC and jurisprudence, perjury requires:
a. A statement under oath on a material matter;
b. Before a competent officer;
c. Willful and deliberate falsity;
d. Required by law or made for a legal purpose.
Venue lies in the locality where the oath-bound false statement is intended to influence judicial decision—that is, where the petition was pending. The mere notarization in Pasig does not control venue. Consequently, the Pasig MeTC lacked jurisdiction to try the perjury charges.
Privileged Nature of Pleadings
Although the MeTC and RTC relied on precedents holding certain statements in pleadings as “absolutely privileged” in libel actions and in civil-action answers not under oath, the Supreme Court observed:
- Flordelis v. Hi
Case Syllabus (G.R. No. 173935-38)
Parties
- Petitioner: Erlinda K. Ilusorio, bona fide chairman and president of Lakeridge Development Corporation (LDC), complainant in the underlying criminal actions.
- Respondents:
• Ma. Erlinda I. Bildner and Lily F. Raqueao, corporate officers who filed the Makati petitions;
• Sylvia K. Ilusorio, Ma. Cristina A. Ilusorio, and Aurora I. Montemayor, corporate officers who filed the Tagaytay petitions.
Factual Background
- Respondents Bildner and Raqueao filed, in Makati City RTC, a sworn petition for issuance of a new owner’s duplicate copy of Condominium Certificate of Title (CCT) No. 21578, alleging loss of the original during office renovations.
- Respondents Sylvia Ilusorio, Cristina Ilusorio, and Montemayor filed, in Tagaytay City RTC, three analogous sworn petitions for new duplicates of Transfer Certificates of Title (TCT) Nos. 17010, 17011, and 17012, likewise claiming loss despite diligent search.
- Petitioner Ilusorio opposed each petition, asserting that she lawfully possessed the originals as LDC’s registered owner.
- Respondents amended their petitions to recite that originals were believed lost, that petitioner opposed and produced the original CCT in court, and that only LDC, not respondents, was entitled to possession.
Criminal Charges and Informations
- Based on the original sworn petitions, petitioner filed before the Pasig City Prosecutor’s Office charges of falsification of public documents and perjury against all respondents.
- Investigating prosecutor dismissed falsification charges but found probable cause for perjury, resulting in four separate Informations