People v. Miranda
REITERATIONFacts
The Antecedents: The accused-appellant, Francisco Miranda, was sentenced by the Court of First Instance of Rizal for the crime of qualified seduction, as defined under Article 443 of the old Penal Code, as amended by Act No. 1773. Procedural History: The accused-appellant filed a motion to dismiss the case, contending that the offended party had completely pardoned the offense against her, invoking Article 344, paragraph 3, of the Revised Penal Code. The Petition: The accused-appellant sought the dismissal of the case based on the alleged pardon granted by the offended party.
Issue(s)
Whether the offended party's pardon of the offender in a seduction case, granted after the criminal action has been instituted, extinguishes the said action according to paragraph 3, article 344 of the Revised Penal Code.
Ruling
The motion for dismissal filed by the accused-appellant is denied. The Court held that the pardon of the offender in a seduction case, after the criminal action has been instituted, does not extinguish said action according to paragraph 3, Article 344, of the Revised Penal Code.
Ratio Decidendi
On Issue 1: The Supreme Court held that paragraph 3 of Article 344 of the Revised Penal Code prohibits a prosecution for seduction, abduction, rape, or acts of lasciviousness only if the offender has been expressly pardoned by the offended party or her authorized representatives before the complaint is filed. The Court meticulously analyzed the wording of the provision, noting that it explicitly states "shall not be prosecuted except upon a complaint filed by the offended party... nor, in any case, if the offender has been expressly pardoned by the above named persons, as the case may be." This phrasing, according to the Court, indicates a condition precedent to the institution of the criminal action. It does not contain any language that prohibits the continuance of a prosecution or orders the dismissal of a case once it has been validly instituted, merely because a pardon is subsequently granted. The Court further clarified that the only act explicitly recognized by Article 344 as extinguishing the penal action and any penalty already imposed, regardless of when it occurs, is the marriage between the offender and the offended party. To bolster its interpretation, the Court referenced its earlier decision in People vs. Infante, G. R. No. 36270, an adultery case, where the same principle was applied: that a pardon, to prevent prosecution under Article 344, must be granted before and not after the penal action has been instituted. Thus, applying this precedent, the Court concluded that a post-institution pardon does not extinguish the criminal action for seduction.
Main Doctrine
The pardon of the offender by the offended party in a seduction case, granted after the institution of the criminal action, does not extinguish the action under Article 344 of the Revised Penal Code. Only the marriage between the offender and the offended party extinguishes the penal action or remits the penalty.