G.R. No. L-23289 - Luansing vs. People

Jovencio Luansing was initially charged with rape in Criminal Case No. 1240 before the Court of First Instance of Batangas (Lipa City Branch) but was subsequently acquitted when the court dismissed the case for lack of evidentiary support for the crime of rape.

The court, however, directed the Provincial Fiscal to file an information for seduction against Luansing within ten (10) days from receipt of the decision, failing which he would be discharged from custody.

On August 15, 1958, Felisa Hernandez, the offended party, filed a complaint for seduction against Luansing.

Based on her complaint, the Provincial Fiscal filed the information alleging that on or about July 10, 1957, in the Barrio of San Roque, Municipality of Sto. Tomas, Batangas, Luansing, by means of deceit and a false promise of marriage, seduced and had sexual intercourse with Felisa Hernandez, a virgin aged over 12 but under 18 years old.

Later, the Fiscal amended the information by changing the alleged date of the offense from July 10, 1957 to July 15, 1957.

During the trial, the private prosecutor reserved the right to file a separate civil action, but subsequently the prosecution was solely handled by the assistant Provincial Fiscal.

The trial court found Luansing guilty beyond reasonable doubt of the crime of seduction and imposed the following penalties:

Indemnity award of P2,000.00 to Felisa Hernandez, with subsidiary imprisonment (not exceeding one-third of the principal penalty) in case of insolvency.

A directive for Luansing to acknowledge his offspring with the offended party and provide a monthly support of P35.00.

Luansing appealed the decision, which was affirmed in its entirety by the Court of Appeals.

Argued that the trial court acted without jurisdiction when it tried the case based on the amended information without a corresponding amended complaint from Felisa Hernandez.

Contended that since the crime of seduction—the penal part—falls under the jurisdiction of the municipal courts (due to its penalty range), the trial court (a Court of First Instance) should not have tried the case.

Claimed that the trial court exceeded its jurisdiction by awarding damages and other civil liabilities (acknowledgment of the offspring and support) when there was a pending reservation by the offended party to file a separate civil action.

Asserted that the amendment changing the date of the offense was a nullity in the absence of a corresponding amended complaint from the offended party.

Whether the amendment of the information changing the date of the offense—from “on or about July 10, 1957” to a specific date of July 15, 1957—was valid without a corresponding amended complaint by the offended party.
Whether the trial court had jurisdiction to try the case, considering the original penalty for the crime of seduction falls within the ambit of municipal courts, despite the inclusion of accessory civil liabilities.
Whether the trial court exceeded its jurisdiction by awarding damages, ordering acknowledgment of the offspring, and imposing support obligations, given that the offended party had reserved the right to file a separate civil action.
Whether procedural fairness was maintained when the trial court allowed the amended information based on the prosecutorial preliminary investigations.