G.R. No. L-58595. October 10, 1983.
PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. RICARDO M. ILARDE, in his capacity as Presiding Judge, CFI of Iloilo, Br. V, CECILE SANTIBANEZ and AVELINO T. JAVELLANA, respondents.

FACTS

The City Fiscal of Iloilo filed an Information dated March 4, 1981, charging Cecile Santibañez and Avelino Javellana with adultery. The Information explicitly stated it was filed “upon sworn complaint originally filed by the offended party Efraim Santibañez,” attaching the sworn complaint (Annex “A”) and a detailed affidavit (Annex “B”) executed by Efraim. The accused filed a motion to quash, arguing the court lacked jurisdiction because the adultery charge was not prosecuted upon a complaint filed by the offended party, as required for private crimes under the Revised Penal Code. They contended that the sworn complaint (Annex “A”) was merely a police blotter and not the formal complaint initiating the prosecution.
The respondent Judge granted the motion to quash. The trial court held that the sworn complaint (Annex “A”) was a mere referral to the fiscal for investigation and not the complaint required by law. It ruled that the filing of the Information by the fiscal alone, without the court having received the sworn complaint of the offended party, was insufficient to confer jurisdiction. The People, through the Solicitor General, elevated the case via certiorari, arguing that the annexes to the Information constituted the requisite complaint.

ISSUE

Whether the trial court acquired jurisdiction over the adultery case, given that the Information filed by the City Fiscal incorporated by reference the sworn complaint of the offended husband.

RULING

Yes, the trial court acquired jurisdiction. The Supreme Court reversed the order quashing the Information. The legal logic is anchored on the principle that for private crimes like adultery, the court’s jurisdiction is conditioned upon the filing of a complaint by the offended party. However, the form and manner of filing this complaint are not rigid. Jurisprudence establishes that the complaint need not be a separate document filed directly with the court; it is sufficient if the sworn statement of the offended party, containing all the allegations necessary under the Rules, is submitted to the court.
In this case, the Information filed by the Fiscal expressly stated it was based on the offended party’s sworn complaint, and copies of that sworn complaint (Annex “A”) and a corroborating affidavit (Annex “B”) were attached as integral parts. These annexes contained all the essential facts constituting the offense of adultery. The Court, citing People v. Lantin, ruled that the filing in court of the sworn statement of the offended party, if it meets the requirements of a criminal complaint under the Rules of Court, constitutes sufficient compliance. The error, if any, was merely the fiscal’s failure to formally present the sworn complaint as a separate filing, which could be easily rectified without dismissing the case. Therefore, the prosecution was validly initiated upon the offended party’s complaint, and the trial court was ordered to proceed with the trial on the merits.