Title
People vs. De Guzman y Villanueva
Case
G.R. No. 229714
Decision Date
Jun 19, 2019
Appellant convicted of two counts of qualified rape against his minor daughter; Supreme Court affirmed conviction, citing credible testimony, medical evidence, and rejecting weak defenses.

Case Digest (G.R. No. 229714)

Facts:

  • Overview of the Case
    • Parties Involved
      • The People of the Philippines, acting as Plaintiff-Appellee.
      • Rolando De Guzman y Villanueva, charged as Accused-Appellant.
    • Nature of the Charges
      • Charged with two counts of qualified rape committed against his daughter, "AAA".
      • The charges incorporate the qualifying circumstances of relationship and minority.
  • Alleged Criminal Acts
    • Incidents Described in the Informations
      • Two separate Informations dated June 20, 2007, alleged rape offenses.
      • The incidents occurred on two different occasions: first around May 13, 2006, and the second in the first week of April 2007.
    • Elements of the Crimes (as per the allegations)
      • Use of force and intimidation.
      • Caramel knowledge (sexual intercourse) against the will of the minor victim.
      • The victim was a minor—14 years old during the first incident and 15 years old during the second.
      • The accused was identified as the biological father of the victim, creating a circumstance of trust and authority.
  • Prosecution’s Version of the Events
    • Details of the First Incident (May 13, 2006)
      • The victim, "AAA", was asleep at home with her siblings and her father.
      • Around 10:30 p.m., she was awakened violently by the appellant who was using a bladed weapon to intimidate her.
      • The sequence of actions included kissing her neck, chest, and breasts; licking her vagina; removal of her bra; pulling down her underwear; and insertion of his penis into her vaginal canal with subsequent ejaculation on her stomach.
      • The use of a weapon and threats of killing were employed to suppress any resistance or attempt to call for help.
    • Details of the Second Incident (First week of April 2007)
      • The victim, already 15 years old, was left at home with her brother while the appellant was present due to her mother’s temporary absence.
      • The incident occurred in the evening when "AAA" was watching television.
      • The appellant forcibly pulled her into the bedroom, offering a narrative of controlling her personal relationships and dictating her conduct.
      • The assault involved a series of actions including caresses, kissing, removal of clothing, and a forceful sexual act involving penetration and ejaculation.
      • The aftermath unfolded when her brother reported the incident to their mother, leading to a subsequent confrontation and confession by "AAA".
    • Corroborative Evidence
      • Medical examination following the second incident revealed significant physical findings (deep healed lacerations at specific positions on the hymen).
      • These medical findings were consistent with the physical abuse described in the victim’s testimony.
  • Defense’s Version of the Events
    • Denial of the Acts
      • The appellant denied committing the acts of rape, asserting a "Not Guilty" plea.
      • He presented a narrative that included an alibi concerning his travel to and from Saudi Arabia and inconsistent recollections of his whereabouts during the alleged incident on May 13, 2006.
    • Alternative Accounts and Explanations
      • Claimed that on the day of the second incident, he had been living separately and had limited interaction with his children.
      • Stated that he had no basis to understand why his daughter would accuse him, emphasizing his reportedly close relationship with his children.
      • The defense's version was found to be less credible in light of the victim’s consistent and detailed testimony and the supporting medical evidence.
  • Trial Court and Appellate Proceedings
    • RTC (Regional Trial Court) Decision (December 23, 2013)
      • The RTC convicted the appellant on two counts of qualified rape after finding that the qualifying circumstances of relationship and minority were proven beyond reasonable doubt.
      • The appellant was sentenced to reclusion perpetua for each count, reflecting the abolition of the death penalty.
      • In addition to the criminal sentence, the RTC imposed civil liability, awarding the victim nominal sums for civil indemnity, moral damages, and exemplary damages.
    • Court of Appeals (CA) Decision (January 22, 2016)
      • The CA affirmed the RTC’s decision with modifications.
      • Modifications included an increase in the monetary awards for damages and a clear declaration that the appellant was not eligible for parole.
      • The CA maintained that the evidence, particularly the victim’s testimony and medical records, proved the element of rape beyond reasonable doubt.
  • Final Appellate Ruling
    • The Supreme Court's Position
      • After reviewing the records, the Supreme Court dismissed the appellant's appeal as bereft of merit.
      • It held that the CA properly affirmed with modifications the RTC decision convicting the appellant of two counts of qualified rape.
    • Emphasis on Established Facts
      • The Court reiterated that the established facts—consisting of the victim’s clear testimony and the medical evidence—were sufficient to uphold the conviction.
      • Affirmed that the victim’s testimony could be accorded full credit due to her youth and immaturity, which traditionally serve as “badges of truth and sincerity.”

Issues:

  • Determination of Guilt
    • Whether the evidence presented by the prosecution established beyond reasonable doubt that the appellant committed two counts of qualified rape against his daughter "AAA".
    • Whether the elements of rape, especially concerning the use of force and intimidation, were adequately demonstrated in both incidents.
  • Evidentiary Credibility
    • Whether the victim's consistent and detailed testimony, corroborated by medical examinations, sufficed to prove the occurrence of the criminal acts.
    • Whether the defense’s presentation of an alibi and denial could effectively counterbalance the credibility of the prosecution’s evidence.
  • Application of Legal Provisions
    • Whether the qualifying circumstances of minority and the relationship between the victim and the offender were correctly invoked and proven.
    • How prevailing jurisprudence regarding the testimony of minors should influence the court’s evaluation of the evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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