C. A. No. L-226 - People vs. Delfin Bautista

The accused, Delfin Bautista, a 30-year-old Doctor of Medicine from San Pablo, Laguna, was married to Josephine Petrack since December 12, 1937, in Vienna.
The household was set up in a three-story building where the upper floor was the bedroom, the middle floor served as the living, dining, and kitchen area, and the first floor accommodated his clinic and his father Enrique Bautista’s office.
The complainant, Concordia Barquilla, born on August 16, 1922, entered the service of Doctor Bautista as a housemaid in December 1938, after her parents incurred an indebtedness of P70 with the defendant’s father.

The complaint alleged that from May 1939 until January 1941, while the complainant was under the age of 18 (until August 15, 1940), Doctor Bautista, using his authority as her employer, seduced her through deceit, trickery, and abuse of confidence.
The seduction occurred when the complainant was a virgin over twelve but under eighteen, which under Article 337 of the Revised Penal Code, constitutes qualified seduction.
The allegations were divided into two distinct periods:

May 1939 to August 15, 1940 – The period in which legal protection under the seduction provisions applied because the complainant was a minor.
August 16, 1940 to January 1941 – The period after she reached majority, rendering the acts immaterial for seduction purposes under the law.

The complaint also noted that after leaving the service on January 18, 1941, the complainant initiated criminal prosecution against the accused.

She initially testified that the first sexual intercourse occurred on the night of May 18, 1939, when the accused returned home after taking his wife out and locked the door, forcing himself upon her.
In subsequent parts of her testimony, she described a pattern of repeated sexual intercourse, allegedly occurring every night or almost every night, over an extended period of one year and eight months.
She also mentioned that she was holding a baby (later clarified to have been a milk bottle) during the first encounter, and later she testified to being seduced again under circumstances that involved threats linked to her family’s indebtedness.
Notably, she admitted that Doctor Bautista had promised to give her P1,000 and to marry her, although she later downplayed the significance of the monetary promise following instructions from her attorney.

On direct examination, she cited specific dates (e.g., May 18, 1939) but later expressed uncertainty regarding the exact dates during cross-examination.
She first said she was holding a baby during the assault, but later explained that it was a milk bottle that was dropped.
Her narrative vacillated between suggesting coercion by threats (e.g., filing a complaint against her parents) and the inducement by promises of money and marriage.

Maria Veridiano, a woman who claimed to have entered the service of the accused as a cook on October 12, 1939, testified that she witnessed the accused embracing the complainant in an upstairs room around 5:00 in the afternoon during May 1939.
She further testified that one week later she observed a similar incident around noontime in the same room.
Her testimony was inherently questionable for several reasons:

Her alleged observations conflicted with the complainant’s account, who claimed the first incident occurred at night.
The logistics of her presence and ability to observe events in a closed bedroom door, as well as the inconsistency regarding her role (cook vs. laundress) in the household, cast doubt on her credibility.

The physical evidence of cohabitation after the complainant reached majority (post-August 15, 1940) was irrelevant for the seduction charge, as under the law seduction is only an offense committed while the victim is a virgin and under eighteen.
The trial court was influenced by the fact that the complainant gave birth on June 8, 1941, attributing paternity to Doctor Bautista, even though the birth resulted from relations occurring after she reached the age of majority.
Legal provisions, notably Article 132 and Article 141 of the Civil Code, preclude the judicial inquiry into the paternity of children conceived after the complainant’s attainment of majority.
There was also a noted resemblance to the case of Infante vs. Figueras, where reliance on paternity evidence was discussed but ultimately deemed improper when it could alter the outcome by shifting the basis to a fact not intended for consideration under the seduction charge.

Whether the prosecution’s evidence, based almost entirely on the uncorroborated and inconsistent testimony of the complainant, was sufficient to overcome the presumption of innocence.

Whether the sexual intercourse or cohabitation that occurred after the complainant reached the age of eighteen (post-August 15, 1940) could validly be considered part of the offense of qualified seduction.

Whether evidence of paternity—specifically the child born on June 8, 1941—could be used to infer guilt for a crime committed when the complainant was still a minor, considering legal restrictions on investigating the paternity of a child conceived after majority.

Whether the inconsistencies and apparent contradictions in the testimony of the complainant, as well as the questionable observations of the corroborating witness, render the overall evidence unreliable for convicting the accused.