People v. Lopez
REITERATIONFacts
The Antecedents: The defendant, Daniel Lopez, was charged with the crime of estupro based on the complaint of Venancia Peralta. The evidence showed that for several years prior to 1904, Venancia Peralta lived in the house of her grandfather, Benedicto Lopez, where the defendant, Daniel Lopez, also resided as the adopted son of Benedicto Lopez. In the spring of 1904, Venancia went to live with her mother and was visited by the defendant. The defendant promised to marry Venancia in early 1904, and thereafter had sexual intercourse with her, resulting in her pregnancy and the birth of a child. After the pregnancy and birth, the defendant, in the presence of witnesses, promised to marry Venancia after completing his studies. Procedural History: The trial court found the defendant guilty of estupro, sentencing him to one month and one day of arresto mayor, to indemnify Venancia Peralta in the sum of P500, to recognize the offspring, and to support the child with P10 per month until majority. The defendant denied the allegations and presented evidence suggesting Venancia had relations with other men. The Petition: The defendant appealed the decision.
Issue(s)
Whether the evidence sufficiently establishes that the seduction was effected with fraud or deceit, an essential element of the crime of estupro. Whether the penalty imposed by the trial court is appropriate.
Ruling
The Supreme Court modified the penalty imposed by the trial court. The defendant was found guilty of estupro and sentenced to two months and one day of arresto mayor, to indemnify Venancia Peralta in the sum of P500, to recognize the child as his, and to support the child by paying P10 per month to her mother until the child's majority, and to pay the costs of the prosecution. The judgment, as modified, was affirmed.
Ratio Decidendi
On the issue of fraud or deceit: The Court found that the evidence was amply sufficient to sustain the trial court's finding that the seduction was effected under a promise of marriage. The relationship between the parties, living in the same household under Benedicto Lopez, to whom the girl was related and who was the defendant's adopted father, indicated a serious nature of the promise to marry. The subsequent conduct of the defendant, particularly his promises to marry after the pregnancy and birth of the child, further supported the conclusion that deceit was present. The Court cited Ballester vs. Legaspi (5 Phil. Rep., 722) in support of its finding that the deceit essential to the crime of estupro was established. The defendant's denial and attempt to discredit the complainant by suggesting relations with other men were insufficient to overcome the evidence presented. On the appropriateness of the penalty: The Court noted that there were neither aggravating nor extenuating circumstances present in the case. According to the applicable law at the time, the penalty for estupro without aggravating or extenuating circumstances should be arresto mayor in the medium degree. The trial court imposed arresto mayor in the minimum degree (one month and one day). The medium degree of arresto mayor ranges from two months and one day to four months. Therefore, the Court modified the sentence to two months and one day of arresto mayor to conform to the medium degree of the penalty.
Main Doctrine
The crime of estupro requires deceit, which can be established by a promise of marriage made under circumstances that indicate its seriousness, especially when followed by sexual intercourse and subsequent conduct inconsistent with the promise.