**Facts:**
1. **Initial Marriage and Separation**: Agueda Benedicto and Esteban de la Rama were married in July 1891 and lived happily until August 1892, when Esteban suddenly took Agueda to her parent’s house, left her there, and never lived with her again.
2. **Divorce Action**: On October 29, 1901, Agueda filed a complaint for divorce citing Esteban’s abandonment and adultery. Esteban responded by denying the allegations of adultery, counterclaimed Agueda’s adultery, and also sought a divorce.
3. **Trial Court Proceedings**: The Court of First Instance of Iloilo ruled in favor of Agueda on July 5, 1902, granting her a divorce and awarding her 81,042.76 pesos as her share of the conjugal property. Esteban appealed, challenging the verdict on the grounds that the findings were unsupported by evidence.
4. **Suspension of Civil Code Titles**: The court assumed that the provisions of the Civil Code relating to divorce were in force. However, it overlooked that Titles 4 and 12 concerning marriage and divorce were suspended in the Philippines by a royal decree on December 29, 1889.
5. **Appellate Process**: Esteban filed for a new trial, which was denied. He then appealed this decision, leading to the present Supreme Court review, which retained all the evidence from the trial.
**Issues:**
1. **Jurisdiction of Divorce Cases**: Whether the Courts of First Instance had jurisdiction over divorce cases.
2. **Applicable Law**: What legal provisions governed divorce in the Philippines at the time of trial.
3. **Evaluation of Evidence**: Whether the trial’s findings of fact were justified based on the evidence presented.
4. **Adultery as Ground for Divorce**: Whether both parties’ conduct constituted acts of adultery invalidating any claim to divorce.
**Court’s Decision:**
1. **Jurisdiction**: The Supreme Court found that the Courts of First Instance have jurisdiction over divorce cases based on pre-1889 legislation and the transfer of authority from ecclesiastical to civil courts after the change in sovereignty.
2. **Legal Basis for Divorce**: The court ruled that the provisions of the partidas applied, establishing adultery as a valid ground for divorce.
3. **Evaluation of Evidence**: The Court disagreed with the lower court’s finding on Agueda’s alleged fidelity. They determined that both Agueda and Esteban committed adultery, based on admissions and evidence, notably Agueda’s incriminating letter expressing guilt.
4. **Adultery and Recrimination**: The Supreme Court held that since both parties were guilty of adultery neither could be granted divorce, based on the principle that one cannot be awarded a divorce if he/she is guilty of the same misconduct.
**Doctrine:**
The case reiterated that under the Spanish Civil Code, confirmed by the partidas, adultery is a ground for divorce. However, both parties’ infidelities invalidate their claims for divorce under the principle of recrimination.
**Class Notes:**
– **Adultery as Divorce Ground**: Adultery allows neither spouse to benefit from divorce if both are guilty.
– **Recrimination**: Under the doctrine of recrimination, a spouse cannot obtain a divorce if they are equally at fault.
– **Historical Legal Context**: Based on transferred jurisdiction to civil courts after severance from ecclesiastical authority.
**Historical Background:**
Dating back to Spanish colonial law, the canon law mixed with civil provisions governed divorce, largely unaltered until American intervention. The suspension of Titles 4 and 12 reflected colonial resistance to civil interference in marital issues, maintaining ecclesiastical prominence in marital separations, which transitioned to civil jurisdiction post-colonization.
This case is a narrative of the collision between the old ecclesiastical dominion over family law with new civil sovereignty in early 20th century Philippines under American governance, setting a precedent for the modern handling of such cases.
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