A crime that others would say turned into a love story prompted the Supreme Court to absolve a convicted rapist, ordering his release from jail after marrying his victim a month after his conviction was affirmed by the court.
In a resolution penned by Associate Justice Antonio Eduardo Nachura, the court’s Third Division accorded Ronie De Guzman the full benefits of Article 89, in relation to Article 344 and Article 266-C of the Revised Penal Code which held that “marriage of the offended woman and the offender in crimes against chastity shall extinguish criminal liability.”
Associate Justices Renato C. Corona, Presbitero J. Velasco Jr., Mariano C. Del Castillo and Jose Catral Mendoza concurred with the ruling.
De Guzman contested the charges against him during more than 10 years of litigation.
On August 19, 2009, De Guzman married his victim in a ceremony held inside the New Bilibid Prisons (NBP) in Muntinlupa City that was officiated by Rev. Lucas Dangatan of Jeruel Christ-Centered Ministries, Inc.
The wedding happened a month after the court affirmed his conviction on two counts of rape.
“Based on the documents, including copies of pictures taken after the ceremony and attached to the motion, we find the marriage between appellant and private complainant to have been contracted validly, legally, and in good faith, as an expression of their mutual love for each other and their desire to establish a family of their own,” the high court said.
The court noted that the first time it decided on a case bearing similar circumstances was in 1974, some 36 years ago.
“On several occasions, we applied these provisions to marriages contracted between the offender and the offended party in the crime of rape, as well as in the crime of abuse of chastity, to totally extinguish the criminal liability of and the corresponding penalty that may have been imposed upon those found guilty of the felony,” the court said.
“Given public policy considerations of respect for the sanctity of marriage and the highest regard for the solidarity of the family, we must accord appellant (De Guzman) the full benefits of Article 89, in relation to Article 344 and Article 266-C of RPC,” it added.
Records showed that De Guzman was sentenced to two life terms by the regional trial Court of Pasig City for raping the victim, who was a relative of his then live-in partner.
De Guzman refuted the rape charges by claiming that he and the victim were actually lovers but they kept their relationship secret since he was then living with his common-law spouse.
During the litigation of the case, the victim maintained that she was raped twice by De Guzman through the use of force and intimidation between the period of May to August 1996.
Nine months after the first rape incident, the victim gave birth to a baby boy in February 1997.
The Court of Appeals, in a ruling issued on March 27, 2008, affirmed the De Guzman’s conviction.