Case Digest (G.R. No. L-47498)
Case Digest (G.R. No. L-47498)
Facts:
Petronilo Ligtas v. The Honorable Court of Appeals and the People of the Philippines, G.R. No. L-47498, May 07, 1987, Supreme Court First Division, Gancayco, J., writing for the Court.Petitioner Petronilo Ligtas was charged with adultery for an incident that occurred on December 14, 1972, when the complainant Tomas Pigte allegedly discovered his wife Lucia Estillore and petitioner in the act of sexual intercourse on a bulldozed hill near their home. Tomas confronted his wife the following morning, and Lucia confessed that the illicit relationship had started in 1969 during Tomas's absence.
After the discovery, Tomas reported the offense to the Chief of Police; the police prepared the complaint and affidavits, but Tomas, citing pity and financial distress, executed an affidavit (Exhibit "C" or Exhibit "3" for the defense) expressing an intention to pardon his wife and petitioner on certain conditions (separation, relinquishment of spousal rights, petitioner supporting the children, etc.). The affidavit was written in English, a language Tomas did not understand and which on its face appeared hastily prepared.
Despite the affidavit, Tomas filed a formal complaint before the Municipal Judge on December 19, 1972. The Court of First Instance of Bohol convicted petitioner of adultery and sentenced him to an indeterminate prison term of two years and four months to five years and six months, plus accessory penalties and damages. The Court of Appeals affirmed the conviction and sentence. Petitioner then filed a petition for certiorari with the Supreme Court to review the Court of Appeals' decision, principally contending that Exhibit "C" amounted to an absolute pardon (either because the conditions were void or should be severed), thereby barring criminal prosecution.
Issues:
- Was Exhibit "C" a valid and effective pardon that barred criminal prosecution for adultery?
- Are the conditions contained in Exhibit "C" void as contrary to law, morals, or public policy so that the affidavit must be treated as an absolute pardon?
- Was the maximum penalty imposed by the trial court proper under Article 334 of the Revised Penal Code and the Indeterminate Sentence Law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)