Title
People vs. De Guzman
Case
G.R. No. 51385-86
Decision Date
Jan 22, 1993
A 70-year-old retired teacher was convicted of raping his 16-year-old housemaid twice in 1974, despite claims of impotence and family presence, leading to reclusion perpetua and support obligations.
A

Case Digest (G.R. No. 51385-86)

Facts:

Accused-appellant Damaso de Guzman, a retired teacher in Calasiao, Pangasinan, was charged with having twice raped the complainant, Virginia Viar, who was sixteen years old at the time of the assaults, at a time when he was already seventy years old. Virginia testified that the first rape occurred on December 15, 1974, when the complainant and the accused-appellant were alone in his house at about midnight because his wife had left with their children to fetch grandchildren in Baguio City. Virginia stated that the accused-appellant entered her room, forced himself upon her despite her resistance, boxed her thighs, removed her panties, and deflowered her, after which he threatened to kill her if she disclosed the incident. The second rape allegedly happened on December 29, 1974, again at about midnight, under practically the same circumstances, except that this time the accused-appellant warned her against disclosure while holding a knife to underscore the threat. Virginia did not inform Mrs. De Guzman or anyone else about either incident, and she continued her employment until January 1, 1975, when, after collecting her salary, she quit and returned home to Dinalaoan, also in Calasiao. She later began vomiting, which prompted her brother Severino to inquire, and when she could no longer conceal the secret, she revealed the two rapes. Severino then caused her medical examination, which on March 10, 1975 showed two healed lacerations in her hymen and pregnancy. On October 3, 1975, she delivered a baby boy, and in the birth certificate she indicated Damaso de Guzman as the father. In defense, the accused-appellant pleaded impotence, asserting that at his age he could no longer copulate or ejaculate, and he claimed that his house was not empty on the dates because his wife, children, and grandchildren were present. He further attacked Virginia’s credibility by invoking her failure to complain and leave immediately, suggesting the pregnancy may have been caused by her half-brother, and insinuating that the accusations were prompted by his refusal to grant another loan to her family. The trial court convicted him on both counts and sentenced him to reclusion perpetua or life imprisonment for each rape, to require him to recognize the offspring, and to pay moral damages of P12,000.00. On appeal, the appellate court affirmed the conviction but modified the penalty and civil liabilities.

Issues:

Whether the evidence was sufficient to establish guilt beyond reasonable doubt for the two counts of rape, and whether the trial court correctly imposed the penalties and civil liabilities, particularly the distinction between reclusion perpetua and life imprisonment, and the order requiring the accused to recognize the child.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.