Title
People vs. De Guzman
Case
G.R. No. 140333-34
Decision Date
Dec 11, 2001
A 7-year-old girl was raped by her maternal uncle in 1998-1999. The Supreme Court upheld the death penalty, citing credible testimony, minor victim status, and familial relationship as qualifying circumstances.

Case Digest (G.R. No. 140333-34)

Facts:

People of the Philippines v. Love Joy De Guzman, G.R. Nos. 140333-34, December 11, 2001, the Supreme Court En Banc, Per Curiam. The prosecution (plaintiff-appellee) charged Love Joy De Guzman (accused-appellant) with two counts of statutory/rape in Criminal Cases Nos. 99-564 and 99-565 for sexual assaults allegedly committed against his seven-year-old niece, Geneva Marie Daugherty, in December 1998 and February 1999 respectively.

The Informations alleged that accused, being the victim’s maternal uncle, with lewd design and taking advantage of the victim’s tender age, had carnal knowledge of the child by force and intimidation. Upon arraignment the accused pleaded not guilty. Trial was before the Regional Trial Court (RTC) of Angeles City, Branch 59; the RTC rendered judgment finding the accused guilty beyond reasonable doubt in both cases and sentenced him to death in each case and ordered indemnity of P75,000 per count. The decision was penned by then Judge Eliezer De Los Santos.

On automatic review to the Supreme Court (owing to the imposition of the death penalty), the accused raised two assignments of error: (1) the Informations were fatally defective for failing to specify the exact dates of the alleged crimes; and (2) the evidence was insufficient to prove guilt beyond reasonable doubt. The trial record shows Geneva’s in-court identification of the accused, detailed testimony describing two separate assaults, medical examination by Dr. Lauro C. Biag docu...(Pro-only)

Issues:

  • Is the Information fatally defective for failing to specify the exact dates of the alleged rapes?
  • Was the conviction supported by evidence proving guilt beyond reasonabl...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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