Case Summary (G.R. No. 232968)
Factual Background
On August 21, 1907, the provincial fiscal filed a written complaint against Felisa Brondial and Juliana Selizar, charging them with perjury. The charge stemmed from allegations made during a civil trial (case No. 090) occurring on February 25, 1907, where Felisa Brondial was a defendant in a case initiated by Agustin Zamora regarding the return of a watch valued at P285. The core of the perjury claim rested on Felisa's declaration of her age as 20 years, which was disputed by her mother, Juliana, claiming her daughter's age to be only 18, while both were aware that Felisa was actually 25 years old.
Judicial Developments
Following a preliminary investigation, the provincial fiscal sought a temporary dismissal of the charge against Juliana Selizar, which was granted. Subsequently, an amended complaint was filed against Felisa Brondial on September 11, 1907. Felisa's defense counsel challenged the validity of the perjury charge through a demurrer, arguing that perjury could not be committed by a party in a civil suit according to legal interpretations, particularly referencing Viada's commentary on the Penal Code.
Court's Consideration of the Demurrer
The demurrer asserted that the facts presented did not constitute criminal perjury in a civil context, leading the lower court to dismiss the case based on this interpretation. The provincial fiscal, however, appealed the dismissal, prompting its escalation to a higher court for further evaluation. Central to the appellate review was whether a party engaged in a civil action who provided false testimony could be held criminally accountable for perjury.
Implications of False Testimony
The court explored precedents indicating that under existing legal frameworks, false testimony given by a litigant is indeed prosecutable. The judgment referenced General Orders, No. 58, and sections of the Code of Civil Procedure, clarifying that parties involved in civil cases could testify and, if found to be lying, face criminal penalties. This was underscored by the principle that allowing litigants to benefit from false testi
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Case Overview
- The case involves the appeal of the provincial fiscal of Albay against the dismissal of perjury charges against Felisa Brondial and her mother, Juliana Selizar.
- The initial complaint was filed on August 21, 1907, alleging perjury committed during a civil trial regarding the return of a watch or its monetary value (P285).
- Felisa Brondial was accused of falsely declaring her age as 20 when she was, in fact, 25, while Juliana Selizar claimed Felisa was only 18.
Procedural History
- After the preliminary investigation, the complaint was filed in the Court of First Instance.
- A request for a temporary dismissal of the charge against Juliana Selizar was granted, allowing a separate complaint to be filed later.
- An amended complaint against Felisa Brondial was filed on September 11, 1907.
- Felisa’s counsel interposed a demurrer, arguing that perjury cannot be committed in a civil case by a party to that case and sought dismissal.
Arguments Presented
- The defense cited the opinion of Viada, a prominent commentato