People v. De Guzman
REITERATIONFacts
The Antecedents: Appellant Ronie de Guzman was indicted before the Regional Trial Court for two counts of rape. Following a trial, the court found him guilty as charged and imposed the penalty of reclusion perpetua for each count, along with civil indemnity. Procedural History: The Court of Appeals affirmed the conviction but modified the award to include moral damages. The appellant then elevated the case to the Supreme Court. In a prior resolution, the Supreme Court dismissed the appeal, affirming the appellate court's decision. Subsequently, the appellant filed a motion for extinguishment of the criminal action and reconsideration. The Petition: The appellant filed a motion to extinguish the criminal action and reconsider the Supreme Court's previous resolution, asserting that he and the private complainant had contracted a valid marriage. He attached a Certificate of Marriage and a joint sworn statement to support his claim. The appellant argued that, pursuant to Article 266-C of the Revised Penal Code, their subsequent marriage should extinguish the criminal action and the penalty imposed. The Office of the Solicitor General interposed no objection.
Issue(s)
Whether the subsequent valid marriage between the Appellant and the private complainant after a conviction for rape extinguishes his criminal liability and the penalty imposed.
Ruling
The motion is GRANTED. Appellant Ronie de Guzman is ABSOLVED of the two (2) counts of rape against private complainant Juvilyn Velasco, on account of their subsequent marriage, and is ordered RELEASED from imprisonment.
Ratio Decidendi
On Issue 1: The Supreme Court (SC) ruled that the subsequent marriage of the offender to the offended party in rape cases results in the total extinguishment of criminal liability. The Court applied Article 266-C of the Revised Penal Code (RPC), which explicitly states that a subsequent valid marriage between the offender and the offended party shall extinguish the criminal action or the penalty imposed. This is further supported by Article 89(7) of the RPC, which lists marriage of the offended woman as a ground for total extinguishment, and Article 344, which provides that marriage remits the penalty already imposed. Based on the Marriage Certificate and the joint sworn statement submitted, the Court found that the marriage was contracted validly, legally, and in good faith as an expression of mutual love. The Court emphasized that public policy considerations regarding the sanctity of marriage and the solidarity of the family require according the appellant the benefits of these legal provisions. Since the marriage was not shown to be void ab initio, the legal conditions for the extinguishment of the criminal action and penalty were fully satisfied, necessitating the appellant's release.
Main Doctrine
The marriage of the offender with the offended party in cases of rape extinguishes the criminal action or remits the penalty already imposed, provided the marriage is contracted validly, legally, and in good faith.