G.R. No. 122740. March 30, 1998 (Case Brief / Digest)

### Title:
**People of the Philippines vs. Winston de Guzman: A Case of Sexual Assault and Credibility of Witness Testimony**

### Facts:
In June 1994, in the Municipality of Governor Generoso, Davao Oriental, Philippines, Winston de Guzman was accused of raping 14-year-old Jovelyn A. Geram. The incident reportedly occurred when Geram was alone at home. De Guzman allegedly entered her residence and assaulted her. Geram recounted the event to neighbors and her mother, who then reported the incident to the police. Medical examination supported her claims, noting injuries consistent with rape. De Guzman’s defense was an alibi, claiming he was in Davao City during the incident. The trial court found him guilty, valuing Geram’s immediate report and consistent testimony over De Guzman’s alibi. De Guzman appealed the decision, highlighting inconsistencies in Geram’s accounts regarding the use of chemicals to facilitate the rape, a detail she mentioned in preliminary investigations but omitted during the trial.

### Issues:
1. The credibility of Jovelyn A. Geram’s testimony given the perceived inconsistencies between her preliminary and trial statements.
2. The sufficiency of evidence to convict Winston de Guzman of rape.
3. The proper procedure for impeaching a witness based on prior inconsistent statements.

### Court’s Decision:
The Supreme Court upheld the trial court’s decision, affirming De Guzman’s conviction based on the credibility of Geram’s testimony and the corroboration by other evidence. It addressed the issue of impeaching a witness through prior inconsistent statements, emphasizing that a proper foundation must be laid during the trial by confronting the witness with the alleged inconsistencies for an explanation. Since De Guzman failed to do so adequately, Geram’s trial testimony stood unassailed. Furthermore, the Court highlighted the principle that evidence not formally offered for consideration during the trial cannot be used to impeach a witness’s credibility. The decision modified the damages awarded to Geram, increasing them in accordance with prevailing case law.

### Doctrine:
The Court reiterated the doctrine regarding the importance of laying a proper foundation when attempting to impeach a witness with prior inconsistent statements. Simply introducing prior statements without giving the witness an opportunity to explain them during the trial is insufficient for impeachment. Additionally, evidence not formally offered during the trial cannot be considered in assessing a witness’s credibility.

### Class Notes:
– **Credibility of Witness**: Immediate reporting and steadfast efforts to seek justice can affirm the credibility of a victim’s testimony over a defendant’s alibi.
– **Impeachment of Witness**: To impeach a witness based on prior inconsistent statements, the statements must be presented to the witness during trial, providing an opportunity for explanation.
– **Formal Offer of Evidence**: Evidence must be formally offered during the trial for it to be considered in judgment. Failure to do so renders the evidence inadmissible for impeaching credibility.
– **Legal Statutes**:
– Rule 132, Section 13, of the Philippine Rules of Court outlines the process for impeaching a witness with inconsistent statements.
– The principle that evidence not formally offered cannot be considered is supported by Section 34, Rule 132, of the Rules of Court.

### Historical Background:
This case exemplifies the Philippine judiciary’s stance on the treatment of victims of sexual violence and the procedural requirements for witness impeachment. It reinforces the legal precedents guiding how inconsistencies in a witness’s statements are to be addressed in court, aiming to ensure fairness and protect the integrity of the witness’s testimony.


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