Facts:

• Ponciano Limcangco is the defendant; Urbana del Rosario is the complainant.
• The events occurred in the Philippines around 1905.
• Limcangco courted Urbana, a woman under 20, and engaged in carnal intercourse with her.
• He promised to marry her.
• By September 1906, Urbana was approximately five months pregnant.
• Limcangco's defense claimed the marriage promise was made after the sexual act, asserting no deceit was involved.
• The lower court found that the promise was made before the sexual relations, supported by letters exchanged.
• Limcangco abandoned Urbana upon learning of her pregnancy and did not fulfill his promise.
• The lower court sentenced him to four months of arresto mayor and ordered him to pay costs, allowing Urbana to seek damages for the unfulfilled promise.
• Both parties appealed the judgment.

Issue:

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Ruling:

• The Supreme Court affirmed the lower court's judgment, finding that deceit was employed in the seduction.
• The court determined that the promise of marriage was made before any sexual relations occurred.
• The sentence was modified to three months of arresto mayor.
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Ratio:

• The court's decision relied on evidence, particularly letters indicating the promise of marriage was made before sexual relations.
• Deceit in seduction does not require formalities; a reasonable belief by the injured party suffices.
• Previous decisions established that a sincere ...continue reading