Title
People vs. Iman
Case
G.R. No. 42660
Decision Date
Sep 12, 1935
Crispin Iman seduced Corazon Arcadio, 17, through a false promise of marriage, leading to a sexual relationship and pregnancy. Despite initial reconciliation attempts, Crispin refused to marry her, resulting in his conviction for seduction under Article 338 of the Revised Penal Code.
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Case Digest (G.R. No. 42660)

Facts:

Courtship and Initial Relationship

  • In June 1932, Crispin Iman began courting Corazon Arcadio, a 17-year-old girl. His efforts were initially unsuccessful, but by August 1932, after persistent pursuit and a promise of marriage, Corazon reciprocated his feelings.
  • Their relationship faced two near-breakups in April 1933 due to Crispin's indecent proposals, but each time, Crispin renewed his promises of love and marriage, reconciling with Corazon.

Sexual Relationship and Deception

  • In May 1933, Crispin visited Corazon's house while her parents were absent. He renewed his promise of marriage and succeeded in having sexual relations with her. Corazon, believing she was already "lost" after the first act, continued to yield to his desires, leading to a carnal relationship.
  • By October 1933, Corazon discovered she was pregnant and confronted Crispin about fulfilling his promise of marriage. Initially, Crispin agreed, but later refused, citing disapproval from his parents and confessor, his lack of love for Corazon, and religious differences (he was Catholic, while her family was Aglipayan).

Intervention and Legal Action

  • Corazon's parents intervened and reported the matter to the chief of police of Plaridel. On November 7, 1933, Crispin renewed his promise to marry Corazon before the chief of police but ultimately refused to fulfill it.
  • Corazon gave birth to a baby boy on March 9, 1934. Letters (Exhibits C, C-1, and C-2) written by Crispin to Corazon in September 1933 corroborated their amorous relationship and his promise of marriage.

Defense Arguments

  • Crispin denied having any amorous relations with Corazon, claiming their interactions were limited to friendly gestures. He also denied being the father of the child, offering implausible explanations for the child's resemblance to him.
  • He alleged that the prosecution was instigated by Aglipayanos due to prior litigation, rather than being based on the merits of the case.

Issue:

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Ruling:

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Ratio:

  1. Elements of Seduction: The crime of seduction requires:

    • Carnal knowledge of a woman above 12 and under 18 years of age.
    • The woman must be of chaste life and good reputation.
    • The act must be accomplished through deceit, typically an unfulfilled promise of marriage.
  2. Promise of Marriage as Deceit: The court held that a promise of marriage, even if made prior to the sexual act and not reiterated at the time, constitutes sufficient deceit if it was the inducement for the woman's consent. The lapse of time between the promise and the act does not negate the offense.

  3. Evidence of Deceit: The court found that Crispin's repeated promises of marriage, coupled with Corazon's resistance to his indecent proposals until she believed in his sincerity, established that her consent was obtained through deceit. The letters and testimony corroborated the existence of the promise and its role in the sexual relationship.

  4. Defense Rejected: The court dismissed Crispin's defense as implausible and lacking credibility. His denial of the relationship and paternity, along with his speculative explanations, were deemed insufficient to counter the evidence presented by the prosecution.

  5. Purpose of the Law: The court emphasized that the statute criminalizing seduction aims to protect young women from being led astray by false promises of marriage, punishing those who exploit such promises to destroy their chastity.


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