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 Summary (G.R. No. 229714)

Antecedent Facts

In separate Informations filed on June 20, 2007, De Guzman was charged with rape, specifically for incidents occurring on or about May 13, 2006, and sometime in early April 2007. The charges described acts of carnal knowledge accomplished through force and intimidation against AAA, who was 14 at the time of the first incident and 15 during the second.

Version of the Prosecution

The prosecution presented evidence that on May 13, 2006, De Guzman sexually assaulted AAA while brandishing a bladed weapon. Despite AAA's pleas for him to stop, he continued the assault. A similar pattern was reported for a second incident in early April 2007, where De Guzman again engaged in sexual acts while overpowering AAA. Witness testimony from AAA, along with medical examinations indicating physical evidence of sexual assault, supported the prosecution’s claims.

Version of the Defense

De Guzman denied the allegations, asserting he was unaware of any wrongdoing during the alleged incidents and claiming a close relationship with his children. He failed to provide a solid alibi, expressing uncertainty about his whereabouts during the specific dates of the alleged rapes.

Ruling of the Regional Trial Court

On December 23, 2013, the Regional Trial Court (RTC) convicted De Guzman of two counts of qualified rape. The court established that the qualifying circumstances of minority and relationship were proven. De Guzman was sentenced to reclusion perpetua for each count and ordered to pay AAA civil indemnity, moral damages, and exemplary damages.

Ruling of the Court of Appeals

The Court of Appeals (CA) affirmed the RTC’s decision on January 22, 2016, with modifications to the damages awarded and declared De Guzman ineligible for parole. The CA placed significant weight on AAA's testimony, reinforcing the RTC's findings and rejecting De Guzman’s defenses.

Our Ruling

Upon meticulous review, the Court finds the appeal lacks merit. It affirms the CA's ruling

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