US v. Coronel · G.R. 4630

Petitioner: US
Respondent: Coronel
Citation: G.R. No. 4630
Court: Supreme Court
Decided: December 19, 1908

Whether adultery prosecution can proceed without complaint from the aggrieved husband

Summary

This 1908 Supreme Court case established that adultery prosecutions require a complaint from the aggrieved husband, not the public prosecutor. Despite evidence of a seventeen-month adulterous relationship between Torcuata Gomez and Ramon Narciso Coronel, the Supreme Court reversed their convictions because the aggrieved husband never filed a complaint. The Court held that under Articles 433-434 of the Penal Code, adultery is a private crime that can only be prosecuted upon the husband's complaint, and the provincial fiscal cannot substitute his complaint for the required husband's complaint. This established important precedent regarding who has standing to prosecute private crimes like adultery under Philippine criminal law.

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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 · December 19, 1908

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