People v. Mantelo · G.R. 29531

Petitioner: People
Respondent: Mantelo
Citation: G.R. No. 29531
Court: Supreme Court
Decided: December 29, 1928

Whether the crime of concubinage can be extinguished by condonation of the offended spouse

Summary

This criminal case involved concubinage charges against a married man and his paramour. The Supreme Court clarified an important distinction in Philippine criminal law: while Act No. 1773 converted adultery and other private crimes into public crimes, concubinage was overlooked and remained a private crime that could be extinguished by condonation of the offended spouse. The Court remanded the case to allow the defense to present evidence that the wife had condoned her husband's extramarital relationship, following the precedent in US vs. Rivera and Vitug. This decision established that condonation remains a valid defense in concubinage cases, distinguishing it from the treatment of adultery under Philippine law.

Related cases

Other Philippine cases on the same provisions and issues.

Valencia v. People G.R. No. 244657
Donio-Teves v. Vamenta G.R. No. L-38308
US v. Bacas G.R. No. 5297
US v. Feliciano G.R. No. 12724
Castro, Jr. v. Court of Appeals G.R. No. L-22159
People v. Pitoc G.R. No. 18513
Maulit v. Samonte G.R. No. 34484
US v. Ananias G.R. No. 9772
US v. Coronel G.R. No. 4630
US v. Pulongbaret G.R. No. 5110
US v. Uri G.R. No. 11371
Francisco v. Tayao G.R. No. 26435

Featured in research

In-depth Intellegal research that discusses this case.

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

By the Intellegal Editorial Board · December 29, 1928

Search Philippine case law on Intellegal →

AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.