Title
People vs. De Guzman
Case
G.R. No. 122740
Decision Date
Mar 30, 1998
A 14-year-old girl was raped by Winston de Guzman in her home; despite his alibi, credible testimony, medical evidence, and witness accounts led to his conviction.

Case Summary (G.R. No. 133250)

Key Dates and Applicable Law

Offense: June 9, 1994.
Arraignment: September 5, 1994.
Decision on appeal: March 30, 1998.
Constitutional and procedural basis: Decision applied the 1987 Philippine Constitution (decision date post‑1990). Relevant procedural rules and authorities invoked include Rule 132, Section 13 of the Rules of Court (on impeachment by prior inconsistent statements), Rule 112, Section 8 (regarding records of preliminary investigation not forming part of the trial court record), and cited jurisprudence (e.g., People v. Resabal; People v. Escosura; Villaruel v. Bascon).

Factual Narrative of the Offense

The information alleged that on or about June 9, 1994 in Governor Generoso, Davao Oriental, appellant, with lewd designs and by means of force, violence and intimidation, had carnal knowledge of Jovelyn Geram against her will. The prosecution’s evidence recounts that Jovelyn was alone in the family residence in the afternoon, was awakened by the weight of something on top of her, saw appellant naked and seated on her thighs, attempted to shout but was silenced by appellant who covered her mouth and threatened to kill her if she resisted. A physical struggle occurred; Jovelyn lost consciousness at a point and later discovered she had been undressed, found blood on her vagina and white fluid on her abdomen and thighs, and felt pain in her genital area.

Medical and Physical Evidence

A municipal resident physician, Dr. Divina Lopez, examined Jovelyn and issued a medical certificate reflecting: (1) positive blood clots on the labia minora; (2) ruptured hymen; and (3) redness around the vulvar area. These findings were introduced as Exhibit A in the folder of exhibits and constituted direct medical corroboration of physical injury consistent with sexual assault.

Prosecution Witnesses and Corroboration

Several witnesses corroborated crucial aspects of Jovelyn’s account and appellant’s presence near the scene. Genesis Delgado testified he observed appellant enter the Geram residence through the rear kitchen door at about 2:00 p.m. and leave about two hours later while Delgado was watching television in the neighboring house. Neighbor Florami Bayno arrived in the evening and Jovelyn later recounted the incident to Florami and to Mauricia and Hugo Bayno. Teacher Enecita (Aniceta) dela Cruz Torion testified she saw appellant with two companions seated on the Geram porch at about 1:00 p.m. These witness accounts placed appellant in the immediate vicinity of the locus criminis during the relevant time frame and supported Jovelyn’s immediate out‑of‑court disclosures.

Defense and Alibi

Appellant raised a denial and alibi defense. He claimed to have been in Davao City from June 6 through June 9, 1994, assisting his mother with a hospitalized sister‑in‑law (an incomplete abortion) and then staying at his sister Christy’s home in Sasa, Davao City, where he allegedly cleaned the house on June 9. He asserted a return to Monserrat only early on June 10. The sole witnesses presented to corroborate the alibi were appellant’s parents, Raul and Violeta De Guzman. Raul additionally claimed to have seen Jovelyn borrow a VHS cassette on the afternoon in question.

Trial Court Findings and Sentence

The trial court credited Jovelyn’s testimony and rejected appellant’s denial and alibi. The trial court relied on Jovelyn’s immediate revelation of the assault, the medical findings, and the testimony of neighbors and other prosecution witnesses who located appellant near the Geram residence at the relevant time. Appellant was convicted of rape and sentenced to reclusion perpetua, ordered to indemnify Jovelyn in the amount of P40,000.00, and to pay costs.

Grounds of Appeal — Alleged Inconsistency

On appeal, appellant contended that Jovelyn’s credibility was undermined by alleged inconsistencies between statements she made during the preliminary investigation and her trial testimony. Specifically, appellant argued that during the preliminary investigation Jovelyn had stated that odorous chemicals were applied to her nose and mouth to induce sleep, whereas at trial she testified the assault was accomplished by force, violence and intimidation. Appellant argued that this inconsistency should destroy her credibility and warrant reversal.

Legal Standard for Impeachment by Prior Inconsistent Statements

The Court reiterated the mandatory procedural rule under Rule 132, Section 13: before a witness may be impeached by proof of prior inconsistent statements, the statements must be related to the witness with particulars (times, places, persons present), the witness must be asked whether he or she made such statements, and the witness must be afforded an opportunity to explain. If the prior statements are in writing, they must be shown to the witness before questioning on them. This foundation (predicate) is essential and is supported by established Philippine and cited foreign jurisprudence. Failure to lay this predicate forecloses impeachment by extrajudicial declarations.

Application of the Impeachment Rule to the Case

The Supreme Court found that the defense failed to comply with the predicate requirement. Although the entire transcript of Jovelyn’s preliminary examination was offered and admitted, the specific portions alleged to contain the “sleep‑inducing chemicals” statements were never identified to Jovelyn during her trial testimony, nor were they read to her and she was not asked to explain them. The complaint containing related statements was not formally offered as evidence at trial and was not part of the exhibits considered by the trial court. Moreover, under Rule 112, Section 8 (1985 Rules of Criminal Procedure), records of the preliminary investigation do not automatically form part of the trial court record; consequently, the trial court properly refused to treat those un‑confronted extrajudicial statements as impeaching evidence. The Court emphasized that it would be unjust to declare Jovelyn an incredible witness on the basis of unpresented or unproved prior statements when she was not given the opportunity at trial to account for any alleged discrepancies.

Evaluation of the Alibi and Credibility Determinations

The Court sustained the trial court’s credibility assessments: Jovelyn’s prompt reporting o

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