G.R. No. 42660; September 12, 1935
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. CRISPIN IMAN, defendant-appellant.

FACTS

The accused, Crispin Iman, courted the complainant, Corazon Arcadio, a 17-year-old girl of chaste life and good reputation. After persistent efforts and a promise of marriage, he succeeded in having carnal knowledge of her in May 1933. The complainant thereafter continued the sexual relationship, believing she was already bound to him. She became pregnant, and when she demanded fulfillment of the marriage promise, the accused refused, alleging his parents’ and confessor’s disapproval, his lack of love for her, and religious differences (he being Catholic, her parents being Aglipayan). The accused had earlier renewed his promise to marry before the chief of police but later reneged. The complainant gave birth to a child in March 1934.

ISSUE

Whether the accused is guilty of the crime of seduction under Article 338 of the Revised Penal Code, where carnal knowledge of a woman above 12 and under 18 years of age, of chaste life, is accomplished by means of deceit—specifically, an unfulfilled promise of marriage.

RULING

Yes. The Supreme Court affirmed the conviction. The essential elements of seduction were present: the complainant was above 12 and under 18, of chaste life and good reputation, and carnal knowledge was accomplished through deceit. The deceit consisted of the accused’s promise of marriage, which induced the complainant’s consent. The Court rejected the appellant’s contention that the promise must be reiterated immediately before the sexual act. It is sufficient that the carnal act was done upon the faith of a previous promise of marriage, even if made months earlier. The accused’s subsequent refusal to fulfill the promise confirmed the deceit. The penalty and civil liabilities imposed by the trial court were affirmed.

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