G.R. No. 243984 - People vs. Agan

The case involves the People of the Philippine Islands as plaintiff and Francisco Miranda as defendant.
Francisco Miranda was previously convicted by the Court of First Instance of Rizal for the crime of qualified seduction under article 443 of the old Penal Code, as amended by Act No. 1773.

The accused-appellant, Francisco Miranda, filed a motion praying for the dismissal of the criminal case.
His main argument was that the offended party had completely pardoned him, invoking article 344, paragraph 3 of the Revised Penal Code as the basis for such dismissal.

Article 344 of the Revised Penal Code (amending article 443 of the old Penal Code) outlines the requirements for the prosecution of crimes such as seduction, adultery, concubinage, abduction, rape, and acts of lasciviousness.
The specific provision in question (paragraph 3) states that offenses like seduction, abduction, rape, or acts of lasciviousness shall not be prosecuted unless there is a complaint filed by the offended party or her parents, grandparents, or guardian, and not if the offender has been expressly pardoned by any of them.
The provision clarifies that, except in the case of marriage between the offender and the offended party—which automatically extinguishes either the criminal action or the imposed penalty—the pardon must be obtained before the prosecution is instituted.

The case cites People vs. Infante (G. R. No. 36270) where, in an adultery case, the First Division held that for the pardon of the aggrieved party to prevent prosecution, such pardon must be granted prior to the filing of the criminal complaint.
This precedent reinforces the interpretation that a pardon given after the institution of the criminal action is not effective in extinguishing the penal proceedings.

Whether the pardon given by the offended party after a criminal case has been instituted is sufficient to dismiss or extinguish the penal action against the offender.
Whether the interpretation of article 344, paragraph 3, of the Revised Penal Code, requiring a pre-prosecution pardon, applies to cases of seduction and similar crimes.

The resolution of the issue determines the scope and timing of the pardon’s effect under the Revised Penal Code.
The decision impacts procedural safeguards and the rights of the offended party in deciding whether to continue or forego criminal prosecution.