Case Summary (G.R. No. L-25176)
Case Background
Yap was convicted for the alleged crime of simple seduction, which was said to occur on or about May 15, 1959, and subsequently involved multiple acts of sexual intercourse with Catalina Babol, a virgin aged between 12 and 18. Following his conviction, Yap appealed to the Court of First Instance of Misamis Occidental, contesting the information presented against him which he argued implied multiple instances of seduction and also incorrectly included details of abortion.
Legal Issues
The primary issue in this appeal centered around the alleged duplicity of offenses in the information presented in the case, specifically whether the prosecution’s information violated the prohibition against duplicity as outlined in Section 12 of Revised Rule 110 of the Rules of Court. The defense contended that the phrasing of the information allowed for the possibility of multiple convictions based on different acts of intercourse, each potentially qualifying as a distinct offense of seduction.
Arguments of the Parties
The defense maintained that the wording of the information—indicating acts "several times"—implied that Yap could be charged with multiple counts of seduction corresponding to each sexual encounter. Conversely, the prosecution contended that simple seduction is completed with the first act of sexual intercourse and that subsequent acts, while immoral, do not constitute additional charges under the law governing seduction. The prosecution further argued that the inclusion of the term "abortion" was unnecessary for the seduction charge.
Judicial Analysis
The court rejected both extreme positions asserted by the defense and the prosecution. It clarified that in cases of simple seduction, the relevant legal requirement does not necessitate that the offended party must be a virgin; rather, it suffices that the complainant is an unmarried woman of chaste life. The court further stated that simply because there were multiple acts of intercourse does not achieve the threshold of multiple offenses unless each act can be independently substantiated as an act of deceit.
Conclusion and Decision
Reviewing the information presente
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Case Overview
- The case involves an appeal by the People of the Philippines against Agapito Yap, Jr. following a ruling by the Court of First Instance of Misamis Occidental concerning the amendment of the information in Criminal Case No. 763.
- The appeal is based on a pure question of law, specifically regarding the prohibition against duplicity of offenses under the Revised Rules of Court.
Facts of the Case
- Agapito Yap, Jr. was convicted by the Municipal Court of Baliangao for simple seduction, as filed by Catalina Babol.
- He was sentenced to two months and one day of arresto mayor.
- The information filed in the Court of First Instance accused Yap of committing simple seduction on Catalina Babol on or about May 15, 1959, and subsequently, which included allegations of deceit and false promises of marriage.
- The information included details of sexual intercourse several times with Catalina Babol, who was a virgin over 12 but under 18 years of age, leading to her pregnancy and subsequent abortion.
Legal Proceedings
- After conviction, Agapito Yap, Jr. filed a motion to quash the information, arguing that it alleged multiple acts of simple seduction and included an offense of criminal abortion.
- The prosecuting fiscal agreed to eliminate t