G.R. No. L-9059; March 14, 1914
THE UNITED STATES, plaintiff-appellee, vs. BUENAVENTURA SARMIENTO, defendant-appellant.

FACTS:
The defendant, Buenaventura Sarmiento, was convicted of the crime of seduction (estupro) and sentenced to four months imprisonment, ordered to pay P500 to the complaining witness Petronila Silverio as civil indemnity, to support any offspring, and to pay costs. Both the accused and Silverio were employees at the Alhambra tobacco factory. On April 29, 1913, before the factory opened, they met at a pre-arranged location, hired a street vehicle, and proceeded to the house of the accused’s friend, Jacinto Rodriguez. There, they stayed in a provided room for about an hour, had breakfast with the Rodriguez family, and then went to work. That afternoon, Silverio, accompanied by her aunt and other relatives, confronted the accused at the factory and demanded he marry her immediately. The group compelled him to go to a minister, who refused to perform the marriage upon learning from the accused’s cedula that he was already married. Criminal proceedings were subsequently initiated.

The information alleged that the accused induced sexual intercourse “by means of deceit, to wit, under promise of marriage.” The sole evidence for this was Silverio’s testimony. She initially stated the promise was made during intercourse, but later added that a promise was also made while they were in the street vehicle en route to Rodriguez’s house.

ISSUE:
Whether the accused is guilty of the crime of seduction (estupro) as defined under Article 443 of the Penal Code, which requires that the carnal knowledge be accomplished “by means of deceit,” specifically, a promise of marriage that induced the complainant to yield her virtue.

RULING:
NO. The Supreme Court reversed the conviction and acquitted the accused.

The Court held that to constitute seduction, the woman must have yielded because of the promise or inducement. If she consented merely from mutual desire or carnal lust, there is no seduction. The deceit (here, the promise of marriage) must be the cause that led her to depart from the path of virtue.

Applying these principles, the evidence failed to prove that the sexual intercourse was induced by a promise of marriage. The complainant’s testimony was neither satisfactory nor convincing. The sequence of eventstheir pre-dawn meeting, immediate hiring of a vehicle, and proceeding to a friend’s house where they were expectedstrongly suggested a pre-arranged plan for illicit relations. The Court found it more probable that Silverio had already decided to surrender herself before entering the vehicle and before any alleged promise was made. Therefore, the intercourse was likely the product of mutual desire, not induced by deceit. Furthermore, evidence suggesting Silverio may have known the accused was married before the act cast additional doubt on her claim that she relied on a promise of marriage.

Since the essential element of deceit was not proven beyond reasonable doubt, the accused must be acquitted. The judgment of the lower court was reversed, and the appellant was acquitted, with costs de officio.