Case Summary (G.R. No. 6668)
Background of the Case
Briones and Carrido were accused of stealing a cow. Prior to their court hearing scheduled for November 15, 1910, Laserna approached Briones in jail and offered him ₱10 to assume responsibility for the theft and alter his testimony. Despite receiving the money, Briones maintained his original statement, affirming that Carrido was involved in the theft. Following these events, the provincial fiscal filed a complaint against Laserna on November 26, 1910.
Judgment of the Lower Court
The Court of First Instance found Laserna guilty of subornation of perjury and imposed a sentence of three months’ imprisonment, a fine of ₱50, disqualification from holding public office for two years, and assessed costs against him. It also ordered the confiscation of the ₱10 given to Briones.
Legal Framework
The applicable law is based on Act No. 1697, which delineates perjury and its subornation. According to Section 3 of the Act, a person commits perjury if they, after taking an oath, willfully provide false testimony. Section 4, on the other hand, states that anyone who causes or procures another to commit perjury is guilty of subornation and subject to the same penalties as for perjury.
Core Legal Issues
The salient legal issue is whether the act of subornation can be construed as punishable in the absence of an actual commission of perjury. The case raises the question of whether inducing someone to commit a crime constitutes a criminal act independent of the successful commission of that crime.
Court Analysis and Conclusion
The court analyzed the circumstances surrounding Laserna's attempt to suborn Briones. Although Laserna provided financial inducement to facilitate false testimony, Briones ultimately repeated his original claims and did not testify falsely. The court held that without Briones committing perjury, the act of subornation could not be deemed complete.
The judgment concludes that the suborner cannot be penalized unless the princi
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Case Overview
- The case centers on Jose Laserna's appeal against a conviction for subornation of perjury.
- The conviction arose from Laserna's alleged attempt to persuade Fausto Briones to provide false testimony regarding a theft case involving a cow.
- The trial was presided over by Judge Mariano Cui in the Court of First Instance of Tayabas.
Background Facts
- Fausto Briones and Estanislao Carrido were co-defendants accused of stealing a cow.
- On the morning of the hearing, Jose Laserna approached Briones in jail, offering him P10 to change his testimony.
- Laserna instructed Briones to deny his previous identification of Carrido as the thief and to assert that he did not know the individual named Estanislao.
- Despite receiving the money, Briones reiterated his prior testimony, affirming Carrido's involvement in the theft.
Procedural History
- Following the incident, the provincial fiscal filed a complaint against Laserna for subornation of perjury on November 26, 1910.
- The Court of First Instance found Laserna guilty, imposing a sentence of three months' imprisonment, a P50 fine, and additional penalties including disqualification from public office and testimony.
Legal Issues Presented
- The primary issue w