Case Summary (G.R. No. 42660)

Legal Definition of Seduction

• The crime of seduction is defined under Article 338 of the Revised Penal Code.
• It involves carnal knowledge of a woman who is over twelve and under eighteen years of age, who has a chaste life and good reputation, achieved through deceit, typically manifested as an unfulfilled promise of marriage.
• Relevant case law supports this definition, establishing that deceit in seduction often takes the form of a promise of marriage that is not fulfilled.

Nature of the Promise of Marriage

• The court clarified that the promise of marriage does not need to be reiterated at the time of the sexual act.
• A prior promise is sufficient to establish the offense, even if the carnal act occurs months later.
• The existence of the promise, regardless of its renewal, is critical in determining the offense of seduction.

Evidence of Consent and Deceit

• Direct testimony from the offended party is not strictly necessary to prove that consent was obtained through deceit.
• The overall conduct of both parties and the circumstances surrounding the case can demonstrate that consent was secured through the promise of marriage.
• The court emphasized that the victim's actions and the context of the relationship are significant in establishing the elements of seduction.

Accused's Liability

• The accused was found guilty of seducing a 17-year-old woman through a false promise of marriage.
• The statute aims to protect young women from seduction that undermines their chastity and virtue.
• The court highlighted the moral reprehensibility of the accused's actions, which involved exploiting the victim's trust.

Factual Background of the Case

• The accused began courting the complainant in June 1932, and after persistent efforts, they engaged in a sexual relationship by May 1933.
• The complainant initially resisted the accused's advances but ultimately succumbed to his repeated promises of marriage.
• After the complainant became pregnant, the accused denied his promise and claimed he was engaged to another woman.

Examination of the Accused's Defense

• The accused contended that the promise of marriage was not reiterated before the sexual act, arguing that this negated the claim of seduction.
• The court found that the promise was indeed reiterated shortly before the first sexual encounter, countering the accused's argument.
• Even if the promise had not been repeated, the initial promise sufficed to establish the offense.

Analysis of Deceit in the Context of Seduction

• The court addressed the argument that the accused used deceitful means, such as administering a potion to the complainant.
• It concluded that there was insufficient evidence to support the claim of administering a potion, and thus, deceit was established through the promise of marriage.
• The court ma...continue reading