People v. Serrano
REITERATIONFacts
The Antecedents: Faustina Ananais, while legally married to Bernardo Alega, engaged in carnal relations multiple times with Agapito Serrano. Serrano was aware of Faustina Ananais's marital status. Procedural History: The Court of First Instance of Tayabas found both Agapito Serrano and Faustina Ananais guilty of adultery and sentenced them to three years, six months, and twenty-one days of prision correccional, with accessory penalties and costs. They appealed this judgment. The Appeal: The defendants appealed the judgment of the Court of First Instance. Their counsel did not deny the facts of the adultery. The defense attempted to present arguments regarding alleged abandonment by the husband and a letter purportedly authorizing the illicit relations, as well as the defense that the sexual intercourse was for a monetary payment.
Issue(s)
Whether the defendants were guilty of the crime of adultery. Whether alleged abandonment by the husband or a letter authorizing illicit relations constitutes a valid defense against the charge of adultery. Whether the plea that sexual intercourse was for a monetary payment is a valid defense against the charge of adultery.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, finding both defendants guilty of adultery. The Court sentenced them to the penalty of three years, six months, and twenty-one days of prision correccional, with accessory penalties and costs. The judgment was declared in accordance with the merits of the case and the law.
Ratio Decidendi
On Whether the defendants were guilty of the crime of adultery: The Court held that it was fully proven that Faustina Ananais, while legally married to Bernardo Alega, lay several times with Agapito Serrano, and that Serrano, knowing the woman was married, also lay with her several times. These facts were not denied by the defense counsel and were expressly admitted by the defendants at the trial. The Court found that the commission of the crime of adultery was not attended by any circumstance that modifies their responsibility, thus affirming their guilt. On Whether alleged abandonment by the husband or a letter authorizing illicit relations constitutes a valid defense against the charge of adultery: The Court ruled that there was no proof that the complainant, Bernardo Alega, abandoned his wife and left her in poverty without means of livelihood. Even if such abandonment had occurred, it could not serve as an excuse or free her from criminal responsibility for her breach of marital fidelity, as she had legal means to compel her husband to fulfill his marital duties. Furthermore, the Court found no proof that the husband wrote the letter presented by the defense, which purportedly authorized her to consort with whomever she pleased and stated his intention not to live with her again. The husband testified that his wife separated from him and refused to resume their marital life despite his entreaties, a statement corroborated by her continued illicit relations even after his return to the locality. On Whether the plea that sexual intercourse was for a monetary payment is a valid defense against the charge of adultery: The Court found that the plea that the woman lay with the man for a money payment, or an immoral agreement, could not justify their conduct or exempt them from criminal responsibility. The Court stated that an immoral consideration, as the price of sexual intercourse, or an immoral agreement, is not an agreement at all in the eyes of the law, nor can it serve to justify a criminal act which, while violating morality and good customs, tends to disturb social order by relaxing family ties. Therefore, this plea was deemed invalid as a ground of defense.
Main Doctrine
The crime of adultery is fully proven when it is established that a married woman has carnal knowledge with a man other than her husband, and the man is aware of her marital status. The Court emphasized that neither an alleged authorization from the husband nor the fact that the sexual intercourse was for a monetary consideration can serve as a defense or exempt the parties from criminal responsibility, as such acts violate morality and tend to disturb social order by relaxing family ties.