Case Digest (G.R. No. 9118)
Facts:
The United States v. Felino Santiago, G.R. No. 9118. November 26, 1913, the Supreme Court, Trent, J., writing for the Court (Arellano, C.J., Torres, Johnson, Carson, and Moreland, JJ., concurring).The appellant, Felino Santiago, was tried in the Court of First Instance of the City of Manila for the crime of seduction and was convicted. The trial court sentenced him to one year eight months and twenty-one days of prision correccional, accessory penalties, indemnity of P500 to the offended party, subsidiary imprisonment in case of insolvency, recognition and maintenance of any offspring, and costs.
The offended party was Benita Mateo, described as a virgin about fourteen years old, who in October 1912 went to Manila to live with her sister Teodora Mateo (wife of Manuel Ilonso) to continue her studies after their mother’s death. Around January 12, 1913, the appellant obtained board and lodging in that household at a modest monthly rate; he was a distant relative and thereafter lived with the family as one household. Benita and the appellant slept in the upper part of the house while Teodora and her husband slept below. The household treated the appellant with confidence until on or about April 2 he was compelled to leave.
About a month before his expulsion the appellant began having illicit intercourse with Benita without the knowledge or consent of Teodora or her husband. The relations continued until the appellant was found in a compromising position with Benita by her father, which led to his expulsion. The prosecution charged that the appellant induced Benita’s consent by solemnly promising to marry her — promises made in deceit to procure carnal relations — and the trial court found the appellant had never intended to marry her.
On appeal the principal contention was one of penalty-classification under Article 443 of the Penal Code: whether the appellant was a “domestic” within the meaning of the first paragraph (which prescribes prision correccional for seduction by certain persons, including “domestic”), or whether he was an “other person” who by deceit seduced a woman and so merited only arresto mayor under the third paragraph. The Court of First Instance convicte...(Subscriber-Only)
Issues:
- Was the appellant a “domestic” within the meaning of Article 443 of the Penal Code so as to subject him to the penalty in the first paragraph (prision correccional) rather than the lesser penalty of arresto mayor in the third paragraph?
- Did the facts — specifically the promise of marriage made to a virgin of about fourteen years to procure sexual relations — establish seduct...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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