Case Digest (G.R. No. 264179) Core Legal Reasoning Model
Facts:
This case involves petitioners Ariel Cadayday Singgit and Genivieve Mayondo But-ay who were charged with and convicted of concubinage by the Municipal Trial Court in Cities (MTCC) of Talisay City, Cebu. The Information dated November 19, 2013, accused Ariel, a married man to Consanita Rubio Singgit, of cohabiting with Genivieve, a woman who is not his wife, in a "private dwelling" and fathering a child with her. Ariel and Genivieve pleaded not guilty and the case proceeded to trial. Evidence presented included multiple testimonies from the private complainant Consanita, neighbors, and friends who saw Ariel and Genivieve living together and recognized their relationship as that of husband and wife. Ariel and Genivieve admitted to their relationship but claimed it was a separate affair wherein Ariel did not reveal his marital status to Genivieve and maintained that they did not live in a conjugal dwelling but in other places such as Mindanao and Negros. The MTCC ruled a
... Case Digest (G.R. No. 264179) Expanded Legal Reasoning Model
Facts:
- Background and Parties Involved
- Petitioners Ariel Cadayday Singgit (Ariel) and Genivieve Mayondo But-ay (Genivieve) were charged with the crime of concubinage before the Municipal Trial Court in Cities (MTCC) of Talisay City, Cebu.
- Ariel is married to Consanita Rubio Singgit (private complainant), with whom he has five children.
- The Information was filed on November 19, 2013, alleging that Ariel, while married to Consanita, unlawfully cohabited with Genivieve, a woman not his wife, and fathered a child with her.
- Factual Antecedents
- Consanita testified that Ariel had multiple mistresses starting around 2008 and that she left their conjugal home due to health and marital issues, relocating to Negros.
- In 2010, Ariel brought Genivieve to live in the conjugal house; they had a child together.
- Consanita witnessed Ariel and Genivieve together in intimate circumstances and had Genivieve summoned to the Barangay Hall where Genivieve admitted to the affair.
- Witnesses Gemma Samlero and Sandra Bacalso corroborated the cohabitation and Ariel’s introduction of Genivieve as his wife to neighbors and the community.
- Ariel admitted to having a relationship with Genivieve but claimed he did not disclose his marriage to her and contended that his wife had separated from him in 2008 and refused to live with him.
- Genivieve testified that she was courted by a man named Rey, later revealed to be Ariel, who promised to marry her but never did, and she was shocked to learn about his existing marriage only when summoned to the barangay.
- Judicial Proceedings
- The MTCC found both Ariel and Genivieve guilty of concubinage.
- The RTC affirmed the MTCC ruling, rejecting the petitioners’ argument that the term "private dwelling" in the Information was insufficient to charge concubinage, stating that it includes conjugal dwelling and other places.
- The Court of Appeals (CA) likewise affirmed the RTC decision, holding that the use of "private dwelling" was immaterial under the third mode of concubinage (“cohabiting … in any other place”).
- Petitioners’ motions for reconsideration were denied by the RTC and the CA. Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45.
Issues:
- Whether the Court of Appeals erred in affirming the conviction of Ariel Cadayday Singgit and Genivieve Mayondo But-ay for the crime of concubinage.
- Whether the use of the term "private dwelling" in the Information, instead of "conjugal dwelling," rendered the Information insufficient to charge concubinage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)