Case Digest (G.R. No. 244657)
Facts:
Michael G. Valencia v. People of the Philippines, G.R. No. 244657, February 12, 2024, Supreme Court Second Division, Lazaro‑Javier, J., writing for the Court.Petitioner Michael G. Valencia was charged with adultery alongside Rubirosa M. Ciocon before the Metropolitan Trial Court in Cities (MTCC) in Criminal Case No. 44965‑03. The information alleged that in December 2001 in General Santos City Rubirosa, then married to Ramon Chito A. Ciocon, willfully had sexual intercourse with Valencia, who knew her to be married. On arraignment Valencia pleaded not guilty; Rubirosa remained at large.
At trial Ramon (the offended husband) testified about his marriage to Rubirosa (August 19, 1991), his work abroad, and later learning that Rubirosa lived with Valencia. Their daughter Monaby testified she saw Rubirosa and Valencia hugging, kissing, sleeping together and once saw Rubirosa on top of Valencia, naked. Valencia denied sexual relations, admitting only that he frequented Ramon’s karinderya and knew the family.
The MTCC, by Decision dated January 18, 2016, convicted Valencia of adultery and sentenced him to prision correccional in its medium period. The MTCC found Monaby credible and held that circumstantial and corroborative evidence sufficed to prove sexual intercourse. The MTCC denied Valencia’s motion for reconsideration by Resolution dated November 16, 2016.
The Regional Trial Court (RTC) affirmed the MTCC in a Decision dated November 24, 2017 and denied reconsideration by Order dated July 20, 2018. The RTC likewise found the elements of adultery established (marriage, knowledge, and sexual intercourse proven by strong circumstantial evidence) and rejected the contention that Ramon’s alleged pardon of Rubirosa extinguished liability.
Valencia filed a petition for review with the Court of Appeals (CA); by Resolution dated October 10, 2018 the CA dismissed his appeal on procedural grounds for multiple defects (unpaid docket/other fees, improper payment instrument, failure to furnish the Office of the Solicitor General, inadequate explanation for service by mail, defective verification/identity of affiant, and failure to append material documents). The CA denied reconsideration on January 15, 2019. Valencia then filed a Rule 45 petition for review on certiorari with the Supreme Court.
Th...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in dismissing Valencia’s appeal for procedural defects, and should this Court relax the procedural rules to entertain his petition?
- Are the questions whether Valencia engaged in the adulterous act and whether the offended husband pardoned his wife reviewable under Rule 45 (i.e., are they questions of law or fact)?
- Was Valencia proven guilty beyond reasonable doubt of adultery under Art...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)