Case Digest (G.R. No. L-58595) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Hon. Ricardo M. Ilarde, the City Fiscal of Iloilo, Ricardo P. Galvez, filed an information on March 4, 1981, charging Cecile Santibanez and Avelino T. Javellana with the crime of adultery under Article 344 of the Revised Penal Code. The complaint was based on two sworn statements by the offended spouse, Efraim Santibanez: one filed on November 4, 1980 with the Integrated National Police (Annex “A”) and another detailed affidavit-complaint on November 7, 1980 (Annex “B”), which described how Santibanez’s son and daughter-in-law orchestrated his wife’s apprehension in flagrante delicto with Javellana in the marital home on November 3, 1980. Despite Santibanez’s unequivocal request in his affidavit that it “be considered as a formal complaint,” he fell gravely ill and died in the United States on February 16, 1981, before the conclusion of the preliminary investigation. Following Fiscal Galvez’s resolution of a prima facie case on February 19, 1981, Case Digest (G.R. No. L-58595) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Allegations
- Efraim Santibanez (offended spouse) legally married to Cecile Santibanez; alleged that on November 3, 1980, Cecile wilfully committed adultery with Avelino T. Javellana in their conjugal home in Iloilo City.
- Complaint (Annex A) filed November 4, 1980 with Integrated National Police, forwarded to City Fiscal Ricardo P. Galvez; affidavit-complaint (Annex B) executed November 6–7, 1980 detailing plan to catch the spouses in flagrante and formally charging them with adultery.
- Preliminary Investigation and Related Events
- January 1981: Efraim learns of terminal illness, executes holographic will disinheriting Cecile for adultery; submits memoranda in investigation.
- February 19, 1981: Fiscal Galvez issues resolution finding prima facie case for adultery; February 16, 1981: Efraim dies in the United States; March 4, 1981: Information for adultery filed in CFI Iloilo, Branch V.
- Motion to Quash and Trial Court Proceedings
- Respondents Cecile Santibanez and Avelino Javellana move to quash on ground that Article 344, RPC and Section 4, Rule 110 RC require complaint by offended spouse, which allegedly was not filed.
- Respondent Judge Ilarde grants motion to quash and dismisses case; fiscal’s motion for reconsideration denied; petition for certiorari filed before the Supreme Court.
Issues:
- Whether the filing and attachment of the sworn complaint-affidavit by the offended spouse satisfied the requirement of Article 344 of the Revised Penal Code and Section 4, Rule 110 of the Rules of Court that adultery “shall not be prosecuted except upon a complaint filed by the offended spouse.”
- Whether the subsequent death of the offended spouse before filing of information deprives the court of jurisdiction absent a new complaint.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)