Case Summary (G.R. No. L-15132)
Charges and Jurisdiction
Rufo B. Cruz was charged before the Court of First Instance of Rizal Province with falsification of a public document. The alleged offense occurred on October 19, 1948, in Cainta, Rizal, when Cruz submitted a sworn application (Civil Service Form No. 2) for the Patrolman Examination administered by the Bureau of Civil Service.
Facts of the Case
Cruz answered under oath that he had never been accused, indicted, or tried for any violation of law or ordinance, despite knowing that he had been previously charged with three criminal cases in the Justice of the Peace Court of Cainta: Crim. Case No. 522 (atentado contra la autoridad), Crim. Case No. 542 (lesiones menos graves), and Crim. Case No. 547 (physical injuries). The bulk of these prior charges dated back to the early 1930s, some were dismissed, while others had been forwarded to a higher court. The response on the application form was patently false, made under oath before the municipal mayor.
Lower Court Proceedings and Appeal
The trial court found Cruz guilty of falsification of a public document and sentenced him to an indeterminate penalty ranging from 4 months and 11 days of arresto mayor to 5 years, 6 months, and 21 days of prision correccional, including fines and accessory penalties. Cruz appealed to the Court of Appeals, which, recognizing the purely legal nature of the issues involved, certified the case to the Supreme Court.
Legal Analysis: Nature of the Offense
The Supreme Court reexamined the offense and held that the proper characterization is perjury, not falsification of a public document. Perjury, as defined under Article 183 of the Revised Penal Code, involves knowingly making untruthful statements under oath on a material matter before a competent officer. The Court cited precedent, specifically United States vs. Tupasi Molina, where similar facts led to a perjury conviction based on falsehoods made in sworn police examination applications. All elements for perjury were present: willful falsehood, oath, knowledge, and materiality. The instructions on the application explicitly warned that false statements under oath expose the applicant to perjury charges.
Prescription of the Crime
The defense argued that the crime of perjury had prescribed under Article 90 of the Revised Penal Code. The Court clarified that crimes punishable with a correctional penalty prescribe within ten years, except arresto mayor offenses which prescribe in five years. Since perjury carries a compound penalty with prision correccional as the highest penalty, the ten-year prescriptive period applies. The crime was committed in 1948, and the case was filed in 1956, well within the ten-year period, thus the prosecution was timely.
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Facts of the Case
- On October 19, 1948, Rufo B. Cruz, the accused and an applicant for the Civil Service Examination for Patrolman, filled out and signed the Philippine Civil Service Form No. 2.
- The form included Question No. 6: “Have you ever been accused of, indicted for or tried for the violation of any law, ordinance or regulation, before any court, or have you ever been charged with or tried for any breach or infraction of military, naval or constabulary discipline before any military, naval or constabulary tribunal or other authority?”
- Cruz answered “No, I have never been accused of any sort whatsoever,” swearing to the truth of this answer before the municipal mayor of Cainta, Rizal.
- It was subsequently proven at trial that Cruz knew he had been previously charged and criminally indicted before the Justice of the Peace Court of Cainta, Rizal, in three criminal cases: Crim. Case No. 522 (atentado contra la autoridad, July 23, 1931), Crim. Case No. 542 (lesiones menos graves, March 13, 1933), and Crim. Case No. 547 (physical injuries, October 19, 1933).
- Case No. 542 was forwarded to the Court of First Instance, while Cases Nos. 522 and 547 were dismissed due to insufficient evidence.
- The accused was charged with falsification of public document based on these facts, tried before the Court of First Instance of Rizal, found guilty, and sentenced accordingly.
Procedural History
- The accused appealed to the Court of Appeals from the judgment of conviction by the Court of First Instance.
- The Court of Appeals, identifying the legal questions as purely legal issues, certified the case to the Supreme Court for final resolution.
- The Supreme Court deliberated on the nature of the offense and the applicability of the defense's claim of prescription.
Issue Presented
- Whether the crime committed by Rufo B. Cruz was falsification of public document or perjury.
- Whether the crime charged had prescribed under the applicable provisions of the Revised Penal Code.
- What penalty should be imposed, considering the crime and circumstances of the case.
Ruling of the Court
- The Supreme Court held that the offense committed was perjury, not falsification of public document