Perjury cannot be willful where the oath is according to belief or conviction as to its truth. A false statement of a belief is not perjury. Bona fide belief in the truth of a statement is an adequate defense. A false statement which is obviously the result of an honest mistake is not perjury. (Villanueva vs. Secretary of Justice, G.R. No. 162187, 18 November 2005, 475 SCRA 495)
