Maulit v. Samonte · G.R. 34484

Petitioner: Maulit
Respondent: Samonte
Citation: G.R. No. 34484
Court: Supreme Court
Decided: December 13, 1930

Whether concubinage can be extinguished by condonation or pardon from the offended spouse

Summary

Fernando Maulit was convicted of concubinage after abandoning his wife to live with a concubine. Despite his wife's formal pardon through a sworn affidavit, he was imprisoned under the theory that Act No. 1773 made concubinage a public offense no longer extinguishable by condonation. His wife filed a habeas corpus petition, which was granted by the Court of First Instance. The Supreme Court affirmed, holding that concubinage was not included in Act No. 1773's list of public crimes and remained a private offense under the Penal Code that could be extinguished by the offended party's pardon. The Court emphasized that criminal statutes must be construed in favor of the accused, and without express legislative intent, concubinage retained its character as a private crime despite similarities to adultery.

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

By the Intellegal Editorial Board · December 13, 1930

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