United States v. Cañet

Summary

The United States prosecuted Federico Cañet for perjury based on a false affidavit he submitted to the Court of First Instance of Iloilo. The trial court dismissed for lack of jurisdiction, reasoning that perjury was completed in Manila where the affidavit was sworn. The Supreme Court reversed, establishing the landmark principle that perjury occurs where false evidence is submitted to mislead a court, regardless of where the affidavit was sworn. The Court held that under Act No. 1697, submitting false sworn evidence in judicial proceedings constitutes perjury in the jurisdiction where the evidence is presented. This decision clarified territorial jurisdiction for perjury cases and strengthened protections against fraudulent court submissions, emphasizing that all faith in judicial proceedings rests upon the sanctity of oath.