Case Digest (G.R. No. 51385-86)
Facts:
People of the Philippines v. Damaso De Guzman, G.R. Nos. 51385-86, January 22, 1993, First Division, Cruz, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the accused-appellant was Damaso De Guzman, a retired teacher.De Guzman was tried before the Court of First Instance of Dagupan City, Branch 3 (Judge Felicidad Carandang-Villalon) on two counts of rape. The trial court found him guilty on both counts, sentenced him to reclusion perpetua or life imprisonment for each rape, ordered him to recognize the offspring of the victim, and awarded the victim moral damages of P12,000.00. The conviction arose from two separate rapes allegedly committed in De Guzman’s house on December 15 and December 29, 1974, against Virginia Viar, then a 16-year-old housemaid employed by the accused.
Virginia testified that on both dates she was alone in the house because De Guzman’s wife and children had gone to Baguio; at about midnight the accused entered her locked room (having the key), forced himself upon her, removed her underwear, deflowered her on December 15, and repeated the assault on December 29 — this time brandishing a knife and threatening to kill her if she told anyone. She later left the employment on January 1, 1975, returned to her hometown, and eventually disclosed the assaults to her brother after beginning to vomit; a medical examination on March 10, 1975 showed two healed lacerations in her hymen and pregnancy. On October 3, 1975 she delivered a son and listed De Guzman as the father on the birth certificate (Exhibits “A” and “B”).
De Guzman defended on the grounds of impotence (claiming at his advanced age he could not copulate or ejaculate), that his house was not empty on the alleged dates (family members were present), that Virginia’s failure to complain or leave indicated consent, and that the pregnancy may have resulted from her half-brother or a family conspiracy prompted by a debt dispute. At trial he testified that before turning 70 (December 11, 1974) he still had sexual relations with his wife “once in a while.” He presented school attendance records of his grandchildren to support the alibi, but his wife did not testify.
The trial court’s judgment was brought befo...(Pro-only)
Issues:
- Was the accused, Damaso De Guzman, guilty beyond reasonable doubt of the two rapes charged?
- Is reclusion perpetua or life imprisonment the proper penalty for the convictions?
- May the accused be compelled to recognize the child born to the complainant, or is he only liable for support?
- Should the award of ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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