Facts:

The case involves two petitions: G.R. No. 96602 filed by Eduardo Arroyo, Jr. and G.R. No. 96715 filed by Ruby Vera-Neri against the Court of Appeals and the People of the Philippines. The events leading to the case began on November 2, 1982, when Dr. Jorge B. Neri filed a criminal complaint for adultery against his wife, Ruby Vera Neri, and Eduardo Arroyo in the Regional Trial Court (RTC), Branch 4, of Benguet. Both defendants pleaded not guilty. After a trial, the RTC convicted Ruby Vera Neri and Eduardo Arroyo of adultery as defined under Article 333 of the Revised Penal Code. The essential facts established by the trial court and the Court of Appeals revealed that on the day of the incident, Ruby Vera Neri, accompanied by a friend, traveled to Baguio City, where Arroyo later joined her at the Neri condominium. Witnesses testified that Arroyo entered the master bedroom where Ruby was present, and after some time, they left together. Following their conviction, both petition...

Facts:

1. Parties Involved:

   • Petitioners: Eduardo Arroyo, Jr. and Ruby Vera-Neri.
   • Respondents: Court of Appeals and the People of the Philippines.

2. Criminal Complaint:

   • Dr. Jorge B. Neri, the husband of Ruby Vera-Neri, filed a criminal complaint for adultery against his wife and Eduardo Arroyo, Jr. under Article 333 of the Revised Penal Code. The alleged act of adultery occurred on November 2, 1982, in Baguio City.

3. Trial Court Proceedings:

   • Both Arroyo and Neri pleaded not guilty. After trial, the Regional Trial Court (RTC) convicted them of adultery. The Court of Appeals affirmed the conviction.

4. Key Evidence:

   • Witnesses testified that Arroyo arrived at the Neri condominium on November 2, 1982, and spent time alone with Ruby Vera-Neri in the master bedroom.
   • Dr. Neri testified that he discovered photographs of his wife and Arroyo in intimate poses, and Ruby admitted to the affair when confronted.

5. Post-Conviction Motions:

   • Arroyo and Neri filed motions for reconsideration, citing Dr. Neri's pardon and his alleged subsequent marriage to another woman. Both motions were denied by the Court of Appeals.

6. Supreme Court Petitions:

   • Arroyo filed a Petition for Review (G.R. No. 96602), which was denied. Neri filed a separate Petition for Review (G.R. No. 96715), which was consolidated with Arroyo’s case.
   • Dr. Neri later filed a manifestation stating he had "tacitly consented" to his wife's infidelity, prompting petitioners to seek dismissal or a new trial.

Issue:

1. Credibility of Dr. Neri’s Testimony:

   • Whether Dr. Neri’s affidavit of desistance casts reasonable doubt on his credibility.

2. Violation of Constitutional Rights:

   • Whether Ruby Vera-Neri’s constitutional right against self-incrimination was violated when her admission to her husband was used against her.

3. Pari Delicto Defense:

   • Whether Dr. Neri’s alleged extra-marital affair precludes him from filing the criminal complaint on the ground of pari delicto.

4. Granting of New Trial:

   • Whether Dr. Neri’s manifestation is sufficient to warrant a new trial or dismissal of the case.

Ruling:

1. Credibility of Dr. Neri’s Testimony:

   • The Supreme Court upheld the credibility of Dr. Neri’s testimony, noting that findings of fact by the trial court and the Court of Appeals are generally binding.

2. Constitutional Rights:

   • The Court ruled that Ruby Vera-Neri’s admission to her husband was not obtained through custodial interrogation, and thus her right against self-incrimination was not violated.

3. Pari Delicto Defense:

   • The Court rejected the pari delicto defense, stating that the concept does not apply to adultery cases under the Revised Penal Code.

4. New Trial:

   • The Court denied the motion for a new trial, finding Dr. Neri’s belated recantation unreliable and insufficient to overturn the conviction.

5. Final Decision:

   • The Supreme Court denied both petitions for lack of merit and affirmed the convictions of Arroyo and Neri for adultery.

Ratio:

1. Credibility of Witnesses:

   • The findings of fact by the trial court and the Court of Appeals, including the credibility of witnesses, are entitled to great weight and are generally not disturbed on appeal.

2. Right Against Self-Incrimination:

   • The constitutional right against self-incrimination applies only during custodial interrogation. Spontaneous admissions made in a non-custodial setting, such as a private conversation between spouses, are admissible.

3. Pari Delicto in Adultery Cases:

   • The doctrine of pari delicto, which applies to contracts with illegal consideration under the Civil Code, does not apply to criminal cases of adultery under the Revised Penal Code.

4. Recantation and New Trial:

   • Recantations by witnesses are viewed with suspicion and are not sufficient grounds for a new trial unless proven to be true and reliable. Dr. Neri’s belated recantation was deemed untrustworthy.

5. Public Policy on Adultery:

   • The prosecution of adultery serves not only to protect the offended spouse but also to uphold the sanctity of marriage and family as fundamental social institutions.