G.R. No. L-23289, February 28, 1969
Jovencio Luansing, petitioner, vs. The People of the Philippines, and The Honorable Court of Appeals, respondents.

FACTS

Jovencio Luansing was originally charged with rape before the Court of First Instance (CFI) of Batangas. The trial court dismissed the rape charge but directed the Provincial Fiscal to file an information for seduction. On August 15, 1958, the offended party, Felisa Hernandez, filed a complaint for seduction, leading to an information alleging that on or about July 10, 1957, the accused, by deceit and false promise of marriage, seduced and had sexual intercourse several times with Felisa Hernandez, a virgin over 12 but under 18 years of age. The Fiscal later amended the information to change the date to July 15, 1957. During the trial, the private prosecutor reserved the right to file a separate civil action, and the prosecution was thereafter handled solely by the assistant Provincial Fiscal. The CFI found Luansing guilty of seduction, sentencing him to four months of arresto mayor, indemnifying the offended party with P2,000, acknowledging the offspring, providing monthly support of P35, and paying costs. The Court of Appeals affirmed the decision in toto. Luansing filed a petition for review, raising three issues: (1) the trial court acted without jurisdiction because the amended information lacked a corresponding amended complaint; (2) the trial court had no jurisdiction, as the crime fell under municipal court jurisdiction; and (3) the trial court exceeded its jurisdiction by awarding damages and civil liabilities despite the reservation to file a separate civil action.

ISSUE

1. Whether the amended information was valid without a corresponding amended complaint.
2. Whether the Court of First Instance had jurisdiction over the crime of seduction.
3. Whether the trial court could award damages and civil liabilities despite the reservation to file a separate civil action.

RULING

1. On the amended information: The amendment changing the date from July 10, 1957, to July 15, 1957, was immaterial. The phrase “on or about” in the original information was comprehensive enough to cover the change, and the substantial rights of the accused were not prejudiced. Thus, the amendment was valid.
2. On jurisdiction: The crime of simple seduction under Article 338 of the Revised Penal Code carries a penalty of arresto mayor (one month and one day to six months), which ordinarily falls under the original jurisdiction of municipal courts. However, Article 345 imposes accessory civil liabilities, including indemnification, acknowledgment of offspring, and support, which are matters beyond municipal court jurisdiction and pertain to the CFI. Citing U.S. vs. Bernardo, the Court held that since the crime of seduction inherently involves these civil liabilities, the CFI has jurisdiction to avoid duplication of proceedings and ensure orderly administration of justice.
3. On the award of damages and civil liabilities: The Court disagreed with the Court of Appeals’ finding that the offended party abandoned her reservation to file a separate civil action by not filing a motion for reconsideration. Abandonment requires more convincing evidence than mere forbearance. Neither party was accorded the chance to present evidence on damages or the amount of support. Therefore, the trial court exceeded its jurisdiction in awarding damages and support. The decision was modified by eliminating these awards.
DISPOSITIVE PORTION:
The decision of the Court of Appeals was modified by eliminating the award of damages and support for the offspring and affirmed in all other respects. No costs were awarded.