G.R. No. 96602. November 19, 1991 (Case Brief / Digest)

### Title:
**Eduardo Arroyo, Jr., et al. vs. Court of Appeals and The People of the Philippines**

### Facts:
On November 2, 1982, in Baguio City, Philippines, an adultery case commenced involving Ruby Vera Neri and Eduardo Arroyo, Jr., with Dr. Jorge B. Neri, Ruby’s spouse, as the complainant. Ruby, along with Linda Sare and another witness, flew to Baguio where they met with Eduardo Arroyo in the evening at the Neri’s condominium. The events that transpired led to a criminal complaint filed by Dr. Neri charging Ruby Vera Neri and Eduardo Arroyo with adultery as defined under Article 333 of the Revised Penal Code. Both defendants pleaded not guilty, but the Regional Trial Court (RTC) of Benguet convicted them.

The adjudication travelled through the judicial hierarchy, with the Court of Appeals upholding the RTC’s decision. Petitioners sought reconsiderations and invoked various arguments including a pardon from the offended spouse, alleged violation of constitutional rights, and inconsistencies in witness testimonies, all of which the Court of Appeals denied. Consequently, separate Petitions for Review were filed before the Supreme Court tagged as G.R. No. 96602 for Arroyo and G.R. No. 96715 for Neri, later consolidated due to their interrelated contentions and facts. Dr. Neri, interestingly, submitted a belated manifestation suggesting his tacit consent to Ruby’s infidelity, a move scrutinized by the Supreme Court in light of the case’s entire dossier.

### Issues:
1. Whether Dr. Neri’s affidavit of desistance and subsequent manifestation could cast doubt on the veracity of the adultery charges.
2. Whether the Constitutional right against self-incrimination was violated in reverence to Ruby Vera Neri’s admission of guilt.
3. Whether Dr. Neri’s purported extramarital affair negates his capacity to charge Ruby Vera Neri and Eduardo Arroyo due to the principle of pari delicto.
4. The relevance and sufficiency of Dr. Neri’s manifestation for a new trial or dismissal.

### Court’s Decision:
The Supreme Court found no compelling reason to diverge from its prior resolution, thereby dismissing the Motion for Reconsideration in G.R. No. 96602 and the Petition for Review in G.R. No. 96715. It established that Dr. Neri’s late affidavit and manifestation did not substantively alter the credence of the allegations. Additionally, it elaborated on the inapplicability of the claimed constitutional violation, noted that the notion of pari delicto does not exempt one from prosecution under these circumstances, and determined that acquiescence or consent, for it to legally suffice as defense, should have been evident prior to the criminal complaint. The Court also forwarded the materials to the Department of Justice for potential perjury evaluation concerning Dr. Neri’s inconsistent statements.

### Doctrine:
The resolution reiterates doctrines on the sanctity of martial fidelity under Philippine law and the procedural policy that once a criminal complaint is lodged by an offended spouse, the control shifts to the prosecutor, thereby emphasizing the state’s vested interest in preserving the fundamental institution of marriage beyond mere private grievances. It also clarified that recantation is highly scrutinized and rarely forms a sole basis for a new trial given its reliability issues.

### Class Notes:
– **Adultery as a Crime:** Requires a complaint by the offended spouse to initiate criminal proceedings, emphasizing the state’s role in marital fidelity cases.
– **Affidavit of Desistance:** Not automatically consequential in criminal cases, especially when filed post-verdict or with questionable genuineness.
– **Pari Delicto:** Inapplicable in criminal cases for adultery or concubinage, underscoring that it relates specifically to contracts under Civil Law.
– **Constitutional Right Against Self-Incrimination:** Not violated in contexts outside custodial interrogation by law enforcement; spontaneous admissions are admissible.
– **Recantation:** Viewed with skepticism due to its potential unreliability; does not necessarily mandate a new trial.

### Historical Background:
This case underlines the consistent affirmation by Philippine judiciary on marital sanctity and the nuanced understanding of consent, pardon, and accusatory privileges in familial legal disputes, juxtaposed against evolving societal norms and the constitutional juxtaposition of individual rights.


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