G.R. No. L-25965 - American Rubber Co. vs. Collector of Internal Revenue

Mariano Fontanilla, the appellant, was prosecuted for qualified seduction before the justice of the peace court (now municipal court) of San Fernando, La Union.
The offended party was Fe Castro, a domestic in Fontanilla’s house, aged 15, a virgin over 12 but under 18 years at the time of the offense.
The complaint, filed on February 28, 1961, alleged that Fontanilla seduced and had sexual intercourse with Fe Castro starting from about September 1960 in the Municipality of San Juan, La Union, taking advantage of his abuse of confidence and authority.
The crime charged carries a penalty of prision correccional.

The lower court found Fontanilla guilty beyond reasonable doubt and sentenced him to an indeterminate prison term from 4 months arresto mayor up to 2 years and 4 months prision correccional.
The court also ordered P500 moral damages to be paid to Fe Castro or her parents.
The appellant appealed to the Court of Appeals, which then certified the case to the Supreme Court due to jurisdictional questions.

Fe Castro was brought by her mother to serve as a helper in Fontanilla’s house from September to shortly before Christmas 1960.
Fontanilla made amorous advances, gave her money, promised to abandon his wife to marry her, and had sexual intercourse with her repeatedly over about three months.
The first sexual intercourse occurred one week after her arrival, during the night when Fontanilla intruded into her bedroom by pushing the wooden bar locking the door.
The illicit relations happened during the day when Fontanilla’s wife was absent and at night while she was asleep.
Fe Castro was frightened and induced by promises of marriage and threats not to complain.
The wife, Magdalena Copio, stated they had sexual intercourse only once a week and denied catching the appellant in a compromising situation.
Mariano Fontanilla denied all allegations of having sexual intercourse, arguing lack of opportunity due to locked room at night and absence during the day, as well as his waning sexual capability at age 52.
The defense suggested the complaint was instigated by Fe Castro’s uncle, Avelino Gapasin, and motivated by envy and a desire for monetary gain.
Attempts to settle the case out of court failed, with a proposed payment of P50 rejected and a demand of P2,000 suggested by Gapasin.

Examination showed incomplete healed lacerations on Fe Castro’s hymen consistent with injuries sustained less than six months prior to February 12, 1961.
The extent and nature of the injuries suggested multiple acts of sexual intercourse (more than ten times).

The appellant argued that the justice of the peace court of San Fernando had no jurisdiction because:

The offense was committed in San Juan, outside the territorial jurisdiction of San Fernando’s court.
Qualified seduction originally falls under the exclusive jurisdiction of the court of first instance, not the justice of the peace court.

The law at the time (RA 296 and RA 2613) gave justice of the peace courts in provincial capitals concurrent jurisdiction over offenses committed within the province where the penalty does not exceed prision correccional.
The appellant’s theory that civil liabilities attach additional penalty affecting jurisdiction was rejected; the jurisdiction depends only on the penalty prescribed for the crime, not on incidental civil liabilities.

Whether the justice of the peace court of San Fernando had jurisdiction to try the case, considering the territorial location of the offense and the nature of the crime.
Whether the prosecution sufficiently proved beyond reasonable doubt that appellant seduced and had carnal knowledge of Fe Castro, including the credibility of the complainant’s testimony.
Whether the delay in the filing of the complaint could affect the credibility of the accusation.
Whether the defense’s denial of opportunity and diminished sexual capacity of the appellant was credible.
Whether the award of moral damages by the lower court was proper and sufficient.