People v. Manzano
REITERATIONFacts
The Antecedents: Dorica Manzano and Venancio Capistrano were charged with the crime of adultery. They pleaded guilty to the charge. Procedural History: The Court of First Instance of Ilocos Sur, considering the guilty plea and lack of education as mitigating circumstances, sentenced each defendant to 2 years, 4 months, and 1 day of prision correccional and to pay one-half of the costs. The complainant, Francisco Ramos (husband of Dorica Manzano), petitioned for a remission of the penalty imposed on his wife, citing compassion for their minor children. This petition was denied. The defendants' counsel also petitioned for the remission of the penalty, arguing that the aggrieved husband was willing to set it aside and that the information was not signed by the complainant. This petition was also denied, leading to the defendants' exception and appeal. The Appeal: The defendants appealed the judgment, alleging that the trial court erred in (first) not dismissing the complaint filed by the prosecuting attorney and (second) not remitting or setting aside the penalty imposed upon them. The first assignment of error was based on the argument that the complaint should have been filed and signed by the aggrieved husband, not the prosecuting attorney, as per Section 1 of Act No. 1773.
Issue(s)
Whether the trial court erred in not dismissing the complaint filed by the prosecuting attorney. Whether the trial court erred in not remitting or setting aside the penalty imposed upon the defendants, despite the aggrieved husband's willingness to pardon.
Ruling
The Supreme Court affirmed the judgment of the lower court, with modifications to the penalty. The Court held that the prosecution was validly initiated and that the penalty imposed was not subject to remission by the aggrieved husband's pardon.
Ratio Decidendi
On Issue 1: The Supreme Court held that the first assignment of error was without merit. The Court found that the aggrieved husband, Francisco Ramos, had indeed filed a complaint against the defendants in the justice of the peace court, which was subscribed and sworn to by him. This initial complaint gave rise to the criminal action and conferred jurisdiction upon the Court of First Instance. Although the formal complaint in the Court of First Instance was filed by the provincial fiscal, this did not invalidate the proceedings, as the action was fundamentally initiated by the aggrieved party as required by Section 1 of Act No. 1773. Therefore, the prosecution was properly instituted by the aggrieved person. On Issue 2: The Supreme Court ruled that the lower court did not err in refusing to remit or condone the penalty imposed upon the defendants. Section 2 of Act No. 1773 explicitly states that condonation, pardon, or remission of penalty by the aggrieved person shall in no way extinguish the liability of the guilty persons to criminal prosecution and punishment, nor shall it operate to dismiss or suspend any prosecution once commenced. Given these categorical provisions, the plea of the aggrieved husband for remission of the penalty was legally ineffective to halt the criminal proceedings or nullify the sentence. The crime of adultery, under Act No. 1773, is treated as a public offense, and its prosecution is governed by the general rules applicable to other crimes, irrespective of private forgiveness.
Main Doctrine
The Supreme Court affirmed that under Act No. 1773, a prosecution for adultery, once commenced upon a complaint filed by the aggrieved party, cannot be extinguished or suspended by the subsequent condonation, pardon, or remission of penalty by the aggrieved person. The Court also held that the filing of a complaint by the aggrieved husband in the justice of the peace court was sufficient to initiate the criminal action, conferring jurisdiction upon the Court of First Instance even when the formal complaint therein was filed by the provincial fiscal.