Title
People vs Bautista
Case
G.R. No. 13946
Decision Date
Feb 5, 1920
A man is found guilty of seducing a minor, and the court rules that the complaint filed by the minor without the intervention of her parents or guardian is valid and lawful.
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Case Digest (G.R. No. 13946)

Facts:

  • In "People vs. Bautista," Tomas Bautista was charged with qualified seduction.
  • The complaint was filed by Marcela Sempio on November 3, 1917, in San Pedro Makati, Rizal Province.
  • Marcela alleged that in February 1915, Bautista, a boarder in her parents' house, seduced her with promises of love and marriage when she was 12 years and 2 months old.
  • Marcela gave birth to a baby girl in June 1916, whom Bautista recognized but later abandoned in May 1917.
  • The preliminary investigation led to the Court of First Instance of Rizal, where an information was filed on December 22, 1917.
  • Bautista pleaded not guilty, but the court found him guilty beyond reasonable doubt.
  • He was sentenced to four months of arresto mayor, ordered to recognize and support his daughter, indemnify Marcela with P500, and pay the costs of the proceedings.
  • Bautista's counsel argued that the complaint was invalid as it was filed by Marcela, a minor, but the motion to dismiss was overruled.
  • The case was appealed to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. Yes, a minor can file a valid complaint for the crime of seduction without the intervention of her parents, grandparents, or guardian.
  2. Yes, the Cour...(Unlock)

Ratio:

  • The Supreme Court ruled that under Act No. 1773, seduction is a public crime and must be prosecuted like other crimes defined by the Penal Code and Philippine legislative acts.
  • The complaint filed by Marcela Sempio, despite her being a minor, was valid and lawful.
  • The court or judge acquired authority and jurisdiction over the accused and the subject matter upon the filing of the compla...continue reading

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