G.R. No. 244657 - Valencia vs. People

Michael G. Valencia (petitioner) and Rubirosa M. Ciocon (co-accused) were charged with adultery under Article 333 of the Revised Penal Code in Criminal Case No. 44965-03.
The charge stated that in December 2001 in General Santos City, Rubirosa, married to Ramon Chito A. Ciocon, had sexual intercourse with Valencia, knowing she was married.
Valencia pleaded not guilty; Rubirosa remained at large.

Ramon testified about his marriage to Rubirosa in August 1991 and their four children.
Due to work as a seaman, Ramon was often abroad; Rubirosa operated a karinderya where she introduced Valencia as a customer.
Ramon found out Rubirosa and Valencia were in a relationship when he returned home after being informed by his mother of familial problems.
Family had moved residences; Monaby, daughter of Ramon and Rubirosa, informed Ramon that Rubirosa lived with Valencia.
Monaby observed Valencia and Rubirosa were affectionate, hugging, kissing, and sleeping together covered by a blanket.
On one occasion, when she was 8 years old, Monaby saw them together in bed, with Valencia naked and Rubirosa on top of him.
Rubirosa admitted to Ramon of being in a relationship with Valencia and eventually left her husband’s family.

Valencia was a supervisor at Ace Foods, had acquaintance with Ramon and Rubirosa through the karinderya business.
Valencia denied having any sexual relationship with Rubirosa.

MTCC (Jan 18, 2016) convicted Valencia based on credible testimony of Monaby and strong circumstantial evidence; sentenced to prision correccional medium period.
MTCC denied Valencia's Motion for Reconsideration, rejecting his arguments on pardon and necessity for direct proof of sexual intercourse.
RTC (Nov 24, 2017) affirmed MTCC's ruling, emphasizing the existence of marriage, Valencia’s knowledge thereof, and circumstantial evidence of sexual intercourse.
RTC denied Motion for Reconsideration on July 20, 2018.

Dismissed Valencia’s appeal on procedural grounds due to failure to comply with multiple procedural requirements including payment of fees and submission of documents.
Denied Motion for Reconsideration stating that mere invocation of "interest of substantial justice" is not sufficient to set aside procedural rules.

Valencia renewed plea for acquittal based on alleged pardon by Ramon, challenging Monaby’s credibility, and contesting failure to prove sexual intercourse.
The Office of the Solicitor General opposed the petition, citing lack of justifiable cause for procedural failures.

Whether or not the Court of Appeals erred in dismissing the appeal on procedural grounds.
Whether the evidence was sufficient to prove Valencia’s guilt beyond reasonable doubt for adultery.
Whether the pardon allegedly granted by Ramon to Rubirosa bars prosecution.
Whether the testimony of Monaby is credible and carries sufficient weight.
Whether the constitutional principle of equality between sexes and related considerations bear on the application of adultery laws.