DIAZ vs.

PEOPLE

191 SCRA 86

FACTS: Reolandi Diaz, then a Senior Clerk at the Jose Abad Santos High School, was
charged with the crime of Falsification of Official Document by stating and making it
appear that he was fourth year Bachelor of Arts student in 1950-1954 in the filing in
the office of the Civil Service Commission for his reappointment as School
Administrative Assistant I of the same school. The accused well knew the statement
to be false and did not reach the fourth year in said course, and consequently his
appointment was approved by reason of said untruthful narration of facts. There
was ample, solid and conclusive evidence presented by the prosecution to prove
that he was not a fourth year A.B. undergraduate.
ISSUE: Whether or not Diaz should be charged with the crime of falsification of
official document.
RULING: No. The accused is found guilty of the crime of perjury defined and
penalized under Art. 183 of the RPC.
RATIO: following the doctrine laid down by People vs. Rufo and US vs. Tupasi Molina,
the crime committed under the foregoing facts, is perjury as defined in art. 183 of
RPC, the willful and corrupt assertion of a falsehood under oath or affirmation
administered by authority of law on a material matter. The elements of such crime
are: (1)accused made a statement under oath or executed an affidavit upon a
material matter; (2) statement or affidavit was made before a competent and duly
authorized officer; (3)accused made a deliberate assertion of falsehood; and (4)
sworn statement or affidavit containing the falsity is required by law or made for a
legal purpose. All of these elements are present in the case at bar.