Monday, July 3, 2023

Case Digest: Jovencio Luansing vs. People and Court of Appeals, G.R. No. L 23289

Jovencio Luansing vs. People and Court of Appeals, G.R. No. L 23289, February 28, 1969

Subject: Obligations and Contracts


FACTS

On August 15, 1958 the offended party, Felisa Hernandez, filed a complaint for seduction against the accused.

On or about the 10th day of July, 1957, in the Barrio of San Roque, Municipality of Sto. Tomas, Province of Batangas, Philippines, and within the jurisdiction of this Honorable Court the above-named accused by means of deceit and false promise of marriage, did then and there wilfully, unlawfully and feloniously seduce and have sexual intercourse several times with one Feliza Hernandez, a virgin over 12 but under 18 years of age.

This information was later amended by the Fiscal to change the date of the alleged commission of the crime from July 10, 1957 to July 15, 1957. During the trial the private prosecutor made a reservation to file a separate civil action and from then on the prosecution was handled solely by the assistant Provincial Fiscal.

The Court a quo subsequently rendered judgment finding the accused guilty beyond reasonable doubt of the crime of seduction.

ISSUE

Whether or not the imposition of civil liability proper, despite the reservation.

RULING

No, it was improper. Abandonment requires a more convincing quantum of evidence than mere forbearance to actually file the civil action, especially considering that the same could be filed even after the decision in a criminal case had been rendered. Besides, the claim for damages requires proof, and contemplates a right on the part of the defendant to present his own rebuttal. As it was, neither the offended party nor the accused was accorded the chance to present evidence on the point. The same is true with regard to the amount of support for the offspring.

No comments:

Post a Comment

Case Digest: General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC, G.R. No. 178647

  General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC,  G.R. No. 178647,  Februa...