People v. Cruz

Summary

Rufo B. Cruz was charged with falsification of public document for stating under oath in his 1948 civil service patrolman application that he had never been accused of violating any law, when he had previously been charged in three criminal cases. The Supreme Court held that the proper crime was perjury under Article 183 of the Revised Penal Code, not falsification, since all elements of perjury were present: willful and corrupt assertion of falsehood under oath on a material matter. The Court rejected the prescription defense, ruling that perjury prescribes in ten years (not five) because the penalty includes correctional imprisonment, and only seven years had elapsed. The conviction was affirmed but the sentence was modified under the Indeterminate Sentence Law to 4 months arresto mayor minimum to 1 year and 1 day prisión correccional maximum. The case established that false statements under oath in government applications constitute perjury rather than falsification of public documents.