People v. Cabero

Summary

Hilaria Cabero was charged with perjury for filing a false sworn complaint against Teresa Santos for physical injuries. The Court of First Instance dismissed the case, ruling it didn't constitute perjury under the Revised Penal Code. The Supreme Court En Banc reversed, holding that the trial court lacked authority to dismiss the complaint sua sponte and that the indictment properly charged perjury under Article 183. The Court ruled that making false statements in a sworn criminal complaint constitutes perjury when done knowingly on material matters before competent authority. The case established that appeals lie from trial court dismissal orders and that unauthorized judicial actions are null and void, not creating jeopardy protection. The dismissal was set aside and the case remanded for proper trial proceedings.