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    People Vs Cruz

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    Jessette Amihope CASTOR
    The accused, Rufo B. Cruz, was charged with falsifying a public document for stating on a civil service application that he had never been accused of violating any law, when he had been previously. The court held that this action constituted perjury, not falsification of a public document, as perjury involves willfully asserting a falsehood under oath on a material matter, as defined in Article 183 of the Revised Penal Code. Prior case law also established that stating falsely on a police examination application that one had never been convicted of a crime, when they had been, was considered perjury. Therefore, the accused was found guilty of perjury rather than falsification.

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    People Vs Cruz

    Uploaded by

    Jessette Amihope CASTOR
    56 views2 pages
    The accused, Rufo B. Cruz, was charged with falsifying a public document for stating on a civil service application that he had never been accused of violating any law, when he had been previously. The court held that this action constituted perjury, not falsification of a public document, as perjury involves willfully asserting a falsehood under oath on a material matter, as defined in Article 183 of the Revised Penal Code. Prior case law also established that stating falsely on a police examination application that one had never been convicted of a crime, when they had been, was considered perjury. Therefore, the accused was found guilty of perjury rather than falsification.

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    3. People vs Cruz

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    The accused, Rufo B. Cruz, was charged with falsifying a public document for stating on a civil service application that he had never been accused of violating any law, when he had been previously. The court held that this action constituted perjury, not falsification of a public document, as perjury involves willfully asserting a falsehood under oath on a material matter, as defined in Article 183 of the Revised Penal Code. Prior case law also established that stating falsely on a police examination application that one had never been convicted of a crime, when they had been, was considered perjury. Therefore, the accused was found guilty of perjury rather than falsification.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    56 views2 pages

    People Vs Cruz

    Uploaded by

    Jessette Amihope CASTOR
    The accused, Rufo B. Cruz, was charged with falsifying a public document for stating on a civil service application that he had never been accused of violating any law, when he had been previously. The court held that this action constituted perjury, not falsification of a public document, as perjury involves willfully asserting a falsehood under oath on a material matter, as defined in Article 183 of the Revised Penal Code. Prior case law also established that stating falsely on a police examination application that one had never been convicted of a crime, when they had been, was considered perjury. Therefore, the accused was found guilty of perjury rather than falsification.

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    People of the Philippines vs Rufo Cruz

    G.R. No. L-15132 May 25, 1960


    Digest by: Jessette Amihope Castor

    Facts:
    Accused Rufo B. Cruz was charged before the Court of First Instance of
    Rizal with the crime of falsification of public document. The record shows
    that the accused Rufo B. Cruz filled up an application blank (Civil Service
    Form No. 2) for the patrolman examination that was given by the Bureau of
    Civil Service on November 13 of that year. The application was signed and
    sworn to by him under oath that he has never been accused of any violation
    of any law, ordinance or regulation before any court, when in fact he has.

    Issue:
    Whether the accused committed perjury?
    Held:
    An applicant for patrolman examination given by the Bureau of Civil
    Service who states under oath that he has never been accused of any
    violation of any law, ordinance or regulation before any court, when in fact
    he has, is guilty of the crime of perjury and not that of falsification of a
    public document. That offense as defined in Article 183 of the Revised Penal
    Code is the willful and corrupt assertion of a falsehood under oath or
    affirmation administered by authority of law on a material matter. The said
    article provides:

    "ART. 183. False testimony in other cases and perjury in solemn


    affirmation. — The penalty of arresto mayor in its maximum period to
    prisión correccional in its minimum period shall be imposed upon any person
    who, knowingly making untruthful statements and not being included in the
    provisions of the next preceding articles, shall testify under oath, or make
    an affidavit, upon any material matter before a competent person authorized
    to administer an oath in cases in which the law so requires.

    "Any person who, in the case of a solemn affirmation made in lieu of an


    oath, shall commit any of the falsehood mentioned in this and the three
    preceding articles of this section, shall suffer the respective penalties
    provided therein."

    This article is similar to section 3 of Act No. 1697 of the Philippine


    Commission, which was formerly the law punishing perjury. Under said
    section 3 of that Act, this Court, in the case of United States v. Tupasi Molina
    (29 Phil., 119), held that a person, who stated under oath in his application
    to take police examination that he had never been convicted of any crime,
    when as a matter of fact he had previous convictions, committed perjury.
    The facts in that case are almost exactly analogous to those in the present.

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