Masangkay v. People

Summary

Eriberto Masangkay was charged with perjury for making allegedly false sworn statements in a petition for involuntary dissolution of Megatel Factors, Inc. He claimed that a December 5, 1992 board meeting never occurred and that a property exchange deed was fictitious. The prosecution relied mainly on meeting minutes and the deed bearing his signature to prove the statements false. The lower courts convicted him, but the Supreme Court reversed on reasonable doubt. The Court held that mere contradictory sworn statements are insufficient for perjury conviction - the prosecution must prove which statement is false by evidence other than the contradictory statement itself. The prosecution failed to present convincing independent evidence that the meeting actually occurred or that petitioner's legal characterization of the deed as 'fictitious' constituted deliberate falsehood rather than legal opinion.