People v. Guzman

Summary

This Supreme Court resolution involves the extinguishment of criminal liability for rape through subsequent marriage. Appellant Ronie de Guzman was convicted of two counts of rape and sentenced to reclusion perpetua with civil indemnity and moral damages. After his conviction was affirmed by both the Court of Appeals and Supreme Court, appellant married the victim Juvilyn Velasco on August 19, 2009. He then filed a motion for extinguishment of criminal action based on Articles 89, 266-C, and 344 of the Revised Penal Code, which provide that marriage between the offender and offended party extinguishes criminal liability in rape cases. The Supreme Court found the marriage to be valid, legal, and contracted in good faith, and granted the motion. The Court emphasized public policy considerations regarding the sanctity of marriage and family solidarity, noting this was the first such case in 36 years. Appellant was absolved of the rape charges and ordered released from imprisonment, demonstrating the continuing application of these Revised Penal Code provisions despite their controversial nature.