This strict delineation between the two crimes is deeply rooted in our jurisprudence. Perjury was described in this wise in the case of Criste B. Villanueva vs. The Hon. Secretary of Justice and Horst-Kessler Von Sprengeisen (G.R. No. 162187, November 18, 2005, Ponente: Honorable Associate Justice Romeo J. Callejo, Sr.), where the Supreme Court explained that “[p]erjury is an obstruction of justice whose perpetration may affect the earnest concerns of the parties before a tribunal, and the felony is consummated the moment the false statement is made.” It requires the concurrent presence of four elements: first, that the accused made a statement under oath or executed an affidavit upon a material matter; second, that the statement or affidavit was made before a competent officer authorized to receive and administer oaths; third, that the accused made a willful and deliberate assertion of a falsehood in that statement; and fourth, that the sworn declaration containing the falsity is required by law or made for a legal purpose.

Conversely, when the untruthful utterance occurs inside a courtroom during a civil suit, a different set of parameters applies. In the case of Ark Travel Express, Inc. v. Violeta Baguio, et al. (G.R. No. 137010, August 29, 2003, Honorable Associate Justice Consuelo Ynares-Santiago), the Supreme Court pronounced that to constitute False Testimony in a civil case under Article 182 of the RPC, the testimony must be given in a civil case, it must relate to the issues presented therein, the statement must be false, the defendant must know of its falsity, and the testimony must be given maliciously with intent to affect the outcome of the case.