G.R. No. 5185

THE UNITED STATES, plaintiff-appellee, vs. BENITO MENESES, defendant-appellant.

September 15, 1909

FACTS:
Benito Meneses was charged with the crime of abduction. The complaint alleged that on September 5, 1908, in Manila, Meneses, with unchaste designs, willfully, unlawfully, and feloniously abducted Leoncia Geronimo, a 17-year-old maiden, from her home for the purpose of carnal intercourse, with whom he actually had such connection.

The lower court found Meneses guilty and sentenced him to one year, eight months, and twenty-one days of presidio correccional and costs. Meneses appealed, questioning the sufficiency of the proof, specifically denying that he induced Leoncia with a promise to marry, that he had carnal intercourse, and thus, that he was guilty beyond reasonable doubt.

The Supreme Court’s examination of the evidence established the following:
1. Leoncia Geronimo was an 18-year-old single girl living with her parents and had been engaged to Meneses for nearly a year.
2. On the evening of September 5, 1908, Meneses induced Leoncia to leave her home surreptitiously under a false promise of immediate marriage. He drove her around Manila for several hours, making excuses about not finding an officer to perform the ceremony.
3. Around 9 PM, he took her to a cochero’s room where they had illicit relations until 11 or 12 PM. Later that night, he took her to other places, eventually sleeping with her in the same bed at an acquaintance’s house.
4. The next morning, Meneses left Leoncia at a relative’s house without explanation and did not return to see her for 10 to 15 days, during which she remained there before returning to her parents’ home.
5. Leoncia had a good reputation, and her submission was clearly due to Meneses’ promise of marriage. The Court found that Meneses accomplished his illegal purpose through fraud and deceit, having no intention of marrying her when he induced her to leave.

ISSUE:
Whether the evidence was sufficient to prove Benito Meneses guilty beyond reasonable doubt of the crime of abduction with unchaste designs under Article 446 of the Penal Code.

RULING:
Yes, the evidence was sufficient to prove Meneses’ guilt.

The Court found that Meneses clearly induced Leoncia to leave her parents’ home under a promise of marriage, without any intention of fulfilling that promise, and subsequently had illicit relations with her under said promise. Citing a Spanish Supreme Court decision, the Court emphasized that for abduction, it is not merely the carnal intercourse that is punished, but the unchaste intent and the offense to public morals and the family by removing a minor maiden from parental vigilance.

The Court held that Meneses’ acts constituted the crime of abduction as defined and punished by Article 446 of the Penal Code.

The lower court’s sentence was modified:
The penalty was changed from presidio correccional to prision correccional (the correct legal term for Article 446).
Meneses was sentenced to one year, eight months, and twenty-one days of prision correccional, with accessory penalties.
He was ordered to pay the offended party P500.
He was ordered to recognize and maintain any offspring should there be any, and to pay the costs.

Subsequent Resolution (October 7, 1909):
After the promulgation of the decision, Meneses filed a petition with the Supreme Court, offering a certificate of marriage celebrated between him and Leoncia Geronimo. The Court, considering this satisfactory proof of marriage and applying Section 2 of Act No. 1773 of the Philippine Commission, ruled that Meneses’ liability and the imposed penalty were extinguished. The Court ordered his immediate release if in custody, or the cancellation of his bail if out on bond.