Title
People vs. Villafuerte
Case
G.R. No. 1181
Decision Date
Apr 27, 1905
Defendants Engracio Villafuerte and Eugenia Rabano are found guilty of adultery despite the lack of a marriage certificate, as the court establishes their marital relationship through witness testimonies and their own acknowledgment of being husband and wife.
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Case Digest (G.R. No. 1181)

Facts:

  • The case "People vs. Villafuerte" involves defendants Engracio Villafuerte and Eugenia Rabano, charged with adultery.
  • The complaint was filed by Felix Villa on April 26, 1902.
  • The incident took place in Lucena, where Villafuerte frequently visited Villa's house, especially when Villa was not present.
  • Three weeks before April 20 of the previous year, Villafuerte moved from his mother's house to Villa's house.
  • On the night of April 20, Villa and Basilio Navela, a local police officer, caught Villafuerte and Rabano lying together in Villa's house.
  • Villa whipped his wife upon discovering them together.
  • A child witness, Maria Origenes, testified seeing Villafuerte and Rabano engaging in carnal intercourse when Villa was absent.
  • Despite the absence of a marriage certificate, multiple witnesses, including those for the defense, affirmed that Villa and Rabano were known as husband and wife.
  • The lower court found both defendants guilty of adultery under Article 433 of the Penal Code.
  • They were sentenced to three years, six months, and twenty-one days of prision correccional, along with the payment of costs.

Issue:

  • (Unlock)

Ruling:

  • The court affirmed the judgment of the lower court, finding Engracio Villafuerte and Eugenia Rabano guilty of adultery.
  • They were sentenced to three years, six months, and tw...(Unlock)

Ratio:

  • The court reasoned that the legitimacy of the marriage relationship between Felix Villa and Eugenia Rabano is a necessary element to establish the crime of adultery.
  • Although no marriage certificate was presented, the court held that the presumption of a legal marriage could be made based on the consistent acknowledgment by both parties and the testimony of witnesses.
  • Both ...continue reading

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