People v. De Guzman

G.R. No. 124368 (June 8, 2000)

Facts:

On January 17, 1995, Henry de Guzman y Pascual was charged with the crime of rape under Article 335 of the Revised Penal Code. The charge stemmed from an incident that occurred on October 30, 1994, in Barangay Salcedo I, Noveleta, Cavite, where the victim, Rosario Lian, then 13 years old, was allegedly raped by the accused.

On the evening of the incident, Rosario and her friend Mary Ann Paredes went to an abandoned house known as the "Kamalig" to meet other friends. After waiting for some time without their friends arriving, Henry approached them and asked to speak with Rosario. He led her to his hut nearby, where he offered her a glass of water. When she entered the hut to get the water, Henry closed the door, began kissing her, and threatened her with a bolo knife, demanding that she not resist. He tied her hands, removed her clothing, and raped her. After the assault, he threatened to kill her if she told anyone about the incident. He later called her boyfriend, Marjon, to the hut and ordered them to sleep there until the following morning.

Rosario did not immediately report the incident but eventually confided in her grandmother, who encouraged her to file a complaint. On November 11, 1994, she underwent a medical examination, which revealed a healing laceration of the hymen, consistent with sexual intercourse.

The defense presented witnesses, including Arnel Luna, who claimed he did not see the accused or the complainant on the night in question. Henry de Guzman denied the allegations, asserting that he had caught Rosario and Marjon in the act of sexual intercourse and that the charges were fabricated to avoid embarrassment.

Legal Issues:

  1. Whether the trial court erred in finding the accused guilty beyond a reasonable doubt of the crime of rape.
  2. Whether the testimony of the complainant was credible and sufficient to support a conviction.
  3. Whether the accused's arrest was lawful and whether the award of moral damages was justified.

Arguments:

Prosecution:

  • The prosecution relied heavily on the testimony of Rosario, which was corroborated by medical evidence indicating sexual intercourse.
  • They argued that the threats made by the accused and the circumstances of the assault demonstrated the use of force and intimidation, fulfilling the elements of rape.

Defense:

  • The defense contended that the prosecution's evidence was inconsistent and lacked corroboration, particularly pointing out that Mary Ann was nearby and could have intervened.
  • They argued that the complainant's testimony was uncorroborated and that the absence of physical injuries suggested that no rape occurred.
  • The defense also claimed that the accused was illegally arrested without a warrant.

Court's Decision and Legal Reasoning:

The Regional Trial Court found Henry de Guzman guilty of rape, sentencing him to reclusion perpetua and ordering him to pay moral damages to the victim. The court emphasized the following points in its decision:

  • The credibility of the complainant's testimony was upheld, as it was consistent and detailed, despite minor inconsistencies that did not detract from its overall reliability.
  • The court noted that the absence of physical injuries does not negate the occurrence of rape, especially when intimidation is involved.
  • The trial court found that the accused's defense of denial was weak and unsubstantiated, lacking any corroborative evidence.
  • The court ruled that the arrest of the accused was moot since it was conducted under a valid warrant, and thus did not affect the trial's outcome.
  • The award of moral damages was justified given the nature of the crime and the victim's age, recognizing the psychological impact of the assault.

Significant Legal Principles Established:

  1. The testimony of a rape victim can be sufficient for conviction if it is credible and corroborated by medical evidence.
  2. The absence of physical injuries does not preclude a finding of rape, particularly when intimidation is present.
  3. Minor inconsistencies in a victim's testimony do not necessarily undermine credibility and may indicate spontaneity.
  4. Moral damages are appropriate in cases of rape, especially involving minors, without the need for proof of mental anguish.