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:

Filing of the Criminal Complaint and Incident Details

• Dr. Jorge B. Neri, the private complainant, filed a criminal complaint for adultery before the Regional Trial Court (RTC), Branch 4, of Benguet.
• The complaint was filed against his wife, Ruby Vera Neri, and Eduardo Arroyo.
• The incident occurred on November 2, 1982, in Baguio City.
• According to the findings, Mrs. Ruby Vera Neri, accompanied by Linda Sare and a witness named Jabunan, traveled by plane to Baguio.
• The group initially stopped at the residence of Mrs. Vera (the petitioner’s mother) at Crystal Cave before proceeding to the Mines View Park Condominium where the Neri spouses resided.
• Around 7:00 p.m., Eduardo Arroyo arrived; he entered the condominium and proceeded to the master bedroom where Ruby Vera Neri and Linda Sare were located.
• Upon Ruby’s request, Linda Sare vacated the master bedroom for the sala, leaving Ruby in the room with Arroyo.
• Approximately forty-five minutes later, Arroyo’s companion rejoined the situation, and the parties eventually left the condominium together.

Procedural Post-Trial Developments

• Both defendants pleaded not guilty at trial; however, the RTC convicted both petitioners of adultery under Article 333 of the Revised Penal Code.
• Following conviction, petitioner Arroyo filed a Motion for Reconsideration challenging the credibility of Mrs. Neri’s admission, among other issues.
• Separately, petitioner Ruby Vera Neri moved for reconsideration or a new trial on the ground that a pardon had been granted by her husband, Dr. Neri, who had later married another woman with whom he was cohabiting.
• The Court of Appeals denied both motions for reconsideration/new trial.

Consolidation and Subsequent Filings

• Petitioner Arroyo filed a Petition for Review (G.R. No. 96602) on February 8, 1991, which was later denied by this Court in a Resolution dated April 24, 1991.
• Petitioner Ruby Vera Neri filed a separate Petition for Review (G.R. No. 96715) on February 19, 1991.
• Subsequent motions for reconsideration and request for consolidation were filed by petitioner Arroyo.
• On June 3, 1991, the cases were consolidated in the Third Division following long-standing practice.
• Later, on July 29, 1991, the Third Division deliberated on the case, and on November 4, 1991, the consolidated cases were re-deliberated by the First Division, which maintained the conclusions previously reached.

Dr. Neri’s Manifestation and Its Implications

• On May 14, 1991, Dr. Neri filed a manifestation asserting he had “tacitly consented” to his wife’s infidelity.
• This manifestation aimed to support the contention of a pardon, thereby questioning the validity of the criminal complaint.
• Both petitioners later sought the dismissal of the case or a new trial on the basis of this late recantation by Dr. Neri, leading to further controversy over the timing and substance of the pardon or consent.

Contentions Raised by the Petitioners

• Petitioner Arroyo argued that:
• Dr. Neri’s affidavit of desistance—stating that the complaint was filed out of a “pure misunderstanding”—casts doubt on his credibility regarding the admission by Mrs. Neri.
• Corroborative testimonies merely established that an illicit affair occurred but did not definitively place adultery on the specific date and location charged.
• The alleged subsequent marriage by Dr. Neri with another woman, if proven, would preclude the spouses from charging one another with adultery or concubinage.
• Petitioner Ruby Vera Neri contended errors committed by the Court of Appeals, including:
• The denial of her motion for reconsideration/new trial.
• The violation of her constitutional right against self-incrimination.
• Failure to address inconsistencies in the testimony of the complaining witness.
• Disregarding medical evidence that purportedly demonstrated her physical inability to have committed the crime charged.

Issue:

• Whether Dr. Neri’s affidavit of desistance, which recants his earlier assertions and claims that the criminal complaint was based on a “pure misunderstanding,” is sufficient to cast reasonable doubts on his credibility.
• Whether Mrs. Neri’s constitutional right against self-incrimination was violated when her admission—made privately in their conjugal home—to having an affair with Eduardo Arroyo was used as evidence at trial.
• Whether Dr. Neri’s allegation of having consented tacitly to his wife’s infidelity (and his subsequent extra-marital actions) precludes the filing or continuation of the criminal complaint on the basis of pari delicto.
• Whether Dr. Neri’s belated manifestation and recantation of his previous statements provide a valid basis for the granting of a new trial or dismissal of the case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)