US v. Uri · G.R. 11371

Petitioner: US
Respondent: Uri
Citation: G.R. No. 11371
Court: Supreme Court
Decided: August 1, 1916

Criminal prosecution for adultery - whether defendants committed adultery and whether prosecution adequately proved essential elements including…

Summary

This landmark 1916 adultery case established important precedents for proving marriage in criminal prosecutions. The Supreme Court affirmed convictions of Cecilia Memoracion and Dalmacio Uri for adultery, ruling that oral testimony of spouses and eyewitnesses can sufficiently prove marriage without documentary evidence. The Court applied the disputable presumption under Act No. 190 that persons cohabiting as husband and wife are legally married, based on defendants' 20-year cohabitation. The decision clarified that knowledge of marriage can be inferred from circumstances, including the accused's frequent visits to the couple's home and community awareness of their relationship. The case demonstrates early Philippine jurisprudence on evidentiary standards in adultery prosecutions and the interplay between criminal law and rules of evidence during the American colonial period.

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Featured in research

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Adultery and Concubinage in the Philippines (RPC Arts. 333-334)

By the Intellegal Editorial Board · August 1, 1916

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