PEOPLE VS DE GUZMAN Y SICO

FACTS: Gilda Ambray filed a case of rape against Gener De Guzman Y Sico. Homeward bound from her
work as a sales clerk, complainant Gilda Ambray was at the gate of Meadow Wood Subdivision, waiting
for a tricycle ride toward her residence. She waited for about ten minutes. When she noticed the accused,
then wearing army pants, sitting at the guardhouse, she approached him and asked him some questions.
The complainant recognized the accused very well because it was summertime and the gate of the
subdivision was well-lit.

After Gilda started to walk, the accused mounted his tricycle, followed her and offered her a ride, to which
she agreed. While on board the tricycle, Gilda noticed that the accused took a different route. She got
scared but managed not to show it. The accused would once in a while stop the tricycle and tell her that
it was not in good condition. When they reached Phase II of the same subdivision near an unfinished
house, the accused stopped and told Gilda to push the tricycle. She alighted from the tricycle and paid
him P5.00, which he did not accept. Gilda then walked away, but after she had taken about ten steps, the
accused embraced her from behind, covered her mouth and held her neck tightly.

(rape followed) (2 attempts were made prior to the act that consummated the rape. The accused did not
succeed on the first 2 attempts because of the complainant’s resistance)

When Gilda arrived home, she told her mother and her husband, Aquilino Flores Ambray, that she was
raped by the accused. They then went to report the incident to the owner of the homeowner’s association
and NBI. Complainant also submitted to physical examinations, the results of which affirmed that there
was a sexual intercourse with force.

Then, Bebey and Linda de Guzman, the parents of the accused, asked the help of Resurreccion Talub
Quiocho, the accuseds kumadre, to beg for Gildas forgiveness for the accuseds sake. The following day,
Resurreccion accompanied the accuseds parents, wife, children and sister-in-law to Gildas house. Gilda
met them, but to their plea for forgiveness, she told them that should not be tolerated.

ISSUE: w/n the plea of forgiveness done by the relatives of the accused amounts to an implied
admission of his guilt?

RULING: YES.

The Court said, “. . . any scintilla of doubt both as to the identification of the accused and as to his guilt
was dissolved by the overtures of his parents, wife, children and sister-in-law on pleading for forgiveness
from Gilda. The accused did not disown their acts, which were testified to by his kumadre, Resurreccion
Talub Quiocho, and Gilda herself. He chose not to deny their testimony. Finally, despite the unequivocal
pronouncement by the trial court that his guilt was strongly established by the acts of his parents, wife
and relatives, who had gone to the house of the victim to ask her forgiveness and to seek a compromise,
the accused dared not assign that finding and conclusion as an error and his Appellants Brief is
conspicuously silent thereon. Indubitably then, the accused was a party to the decision to seek for
forgiveness, or had prior knowledge of the plan to seek for it and consented to pursue it, or confirmed
and ratified the act of his parents, wife, children and sister-in-law. A plea for forgiveness may be
considered as analogous to an attempt to compromise. In criminal cases, except those involving quasi-
offense (criminal negligence) or those allowed by law to be compromised, an offer of compromise by the
accused may be received in evidence as an implied admission of guilt. No one would ask for forgiveness
unless he had committed some wrong, for to forgive means to absolve, to pardon, to cease to feel
resentment against on account of wrong committed; give up claim to requital from or retribution upon
(an offender). In People vs. Calimquim, we stated:

The fact that appellants mother sought forgiveness for her son from Corazons father is an indication of
guilt. “

PEOPLE V ABADIES Y CLAVERIA

FACTS: Accused-appellant stands charged with violation of Republic Act No. 7610 or The Special
Protection of Children Against Child Abuse, Exploitation and Discrimination Act

Accused JOSE ABADIES y CLAVERIA commit acts of lasciviousness upon the person of his 17-year old
daughter ROSALIE ABADIES Y MANUNGHAYA by kissing, mashing her breast and touching her private parts
against her will and consent.

The facts show that accused-appellant has been living for the past twenty years with his common-law
wife, Catalina Manunghaya, together with their two children, Jonathan and complainant Rosalie. The
family sleeps together in one room and usually Catalina wakes up early in the morning to buy bread. It
was during these short periods of time while Catalina was out of the house that the abuses took place. On
the dates material to these cases, complainant was 17 years old.

Accused-appellant proffered the defense of denial and alibi. He denies having committed acts of
lasciviousness against complainant. He testified that on the dates of the alleged incidents, he woke up
between 7:00 to 7:30 a.m.; that complainant and her mother were already preparing breakfast; and after
eating breakfast, he would leave for work. He also testified on the reason why the charges at bar were
filed against him. Allegedly, on July 26, 1997, he asked complainant what was happening to their lives as
his children were aloof with him. Complainant threatened to end her life because she felt she was to be
blamed for their problems. Accused-appellant also declared he was too strict with his children, and even
inflicts physical harm on them when they disobey him.

In the present appeal, accused-appellant asserts that the court a quo erred in finding the prosecution's
version more credible and in convicting him despite the implied pardon given by complainant. Accused-
appellant likewise contends that there exists no factual basis for the trial court to consider his plea of
forgiveness in his letter to complainant as an implied admission of guilt.

ISSUE: w/n the plea of forgiveness may be admitted as an implied admission of guilt

RULING:

YES.

A cursory reading of the relevant parts of the letter will readily show that accused-appellant was
indeed seeking pardon for his misdeeds. Some of the pertinent portions read as follows: "I
made this letter to ask your 'forgiveness. x x x Alam mo bang sobra-sobra na ang pagsisisi ko
sa ginawa kong iyon. x x x Parang awa mo na Ne hirap na hirap na ako at ang lahat ay buong
puso ko ng pinagsisisihan. Patawarin mo na ako anak. x x x." There is no iota of doubt that
accused-appellant was asking forgiveness for having committed the acts with which he now
stands charged. Settled is the rule that in criminal cases, except those involving quasi-offenses
or those allowed by law to be settled through mutual concessions, an offer of compromise by
the accused may be received in evidence as an implied admission of guilt. Evidently, no one
would ask for forgiveness unless he had committed some wrong and a plea for forgiveness may
be considered as analogous to an attempt to compromise. Under the circumstances, accused-
appellants plea of forgiveness should be received as an implied admission of guilt.
PEOPLE VS PRADES

FACTS: Private complainant Emmie R. Rosales was seventeen years old when the dastardly outrage
befell her. She testified that she and her younger sister, Melissa, were asleep in a room in their house
and were then the only persons at home because their grandfather, who lived with them, was in the
hospital at that time.

At around midnight, complainant suddenly awoke as she felt a heavy weight pressing down upon
her. She thereupon realized that a man, clad only in his underwear, lay on top of her. She was about to
shout when he poked a gun at her neck and warned her not to create any noise or he would kill her.

Although the house lights were off, moonlight streamed through the sawali door of the room, enabling
complainant to see the intruder. She recognized him as appellant Senen Prades, her barriomate. It
appears that he gained entry into the house through a passageway in the kitchen.

Then the accused succeeded in raping the victim.

Several days later, complainant received two letters from appellant. She saw appellant hand the first
letter to her grandmother who later gave it to her. The other letter was given by appellant to
complainant through the latters sister. Aggrieved by all these circumstances, complainant decided to
disclose to her grandfather the sexual assault.

appellant escaped from confinement before the prosecution had completed the presentation of its
evidence. A general warrant of arrest was issued for his apprehension and it was ordered that he be
included in the list of wanted criminals. Appellant, however, has not been recaptured up to now

ISSUE: w/n the letters sent by the accused to the victim served as an admission of his guilt

RULING:

YES.
it is conceded that after the rape, he sent complainant two letters in which he implored her forgiveness
and offered to leave his wife so that he could be with her. In fine, appellant sealed his own fate by
admitting his crime under the seal of a virtual confession in fact, if not in law.

In criminal cases, except those involving quasi-offenses or those allowed by law to be settled through
mutual concessions, an offer of compromise by the accused may be received in evidence as an implied
admission of guilt. For this rule to apply, it is not necessary that a complaint be first filed by the victim
because all that is required is that after committing the crime, appellant or his representative makes an
offer to compromise and such offer is proved
 Evidently, no one would ask for forgiveness unless he had committed some wrong and a plea for
forgiveness may be considered as analogous to an attempt to compromise. The letters of appellant
containing an appeal for condonation of his acts cannot but be construed as an implied admission of his
guilt.
The Court is persuaded that appellant sent complainant the letters introduced in evidence by the
prosecution and that said letters contained an admission of his guilt, thus confirming his
culpability. If appellant did not forcibly rape complainant on the night of March 24, 1994, complainant
may possibly have accepted appellants offer to live with her. At the very least, she would not have
revealed her misfortune so as not to expose the despoliation of her virtue. That complainant chose to
divulge the incident and subject herself to the disgrace of public scrutiny and scandal buttresses the
charge that she had been criminally ravished by appellant.
Further, because no evidence was presented by the defense to discredit this affirmation of guilt
derived from the contents of the letters, the authenticity of said letters is no longer open to question. The
letters thus bolster and corroborate complainant’s testimony on the identity and guilty of appellant.
Another factor supporting appellant’s conviction is his flight. By escaping from confinement during
trial and failing to turn himself in despite his subsequent conviction by the trial court, and despite the
standing warrant of arrest, appellant has become a fugitive from justice.

PEOPLE VS ERGUIZA

FACTS:

While AAA was trying to unhook her short pants, Larry suddenly grabbed and pulled her. Poking a knife
at her neck, Larry threatened to hurt her if she would make a noise.

Accused-appellant dragged AAA towards a place where a tamarind tree and other thorny plants grow.
Then Larry removed his maong pants and forced AAA to lie down on the grassy ground. Thereafter, he
removed her short pants and panty, mounted himself on top of her and inserted his penis into her
private parts and made push and pull movements. He likewise raised AAAs sandoand mashed her
breast. AAA felt pain when accused-appellant entered her and she felt something sticky in her private
part after Larry made the push and pull movements.

Victim got pregnant.

CCC (AAA's father), testified that the family of accused-appellant went to their house and initially
offered P50,000 and later P150,000; that in January 5, 2000, while they were repairing his house for the
wedding reception. Larry left at around 4:00 o'clock p.m.

Defense however claimed that accused could never be on the crime scene since he was with his wife
while giving birth and that he never left her side.

This was corroborated by the hilot and the victim’s friend who testified that she never left the victim
when her shorts got hooked; that they went together to the store of Auntie Beth where they parted.

Family of the accused also claimed that it was because the other sister of the rape victim was supposed
to marry their other son, brother of accused, but they had an altercation regarding the bills for the
wedding. So the victim’s family tries to falsely accuse his other son of the rape for revenge.
Moreover, the testimonies of the witnesses for both the prosecution and the defense conflict on certain
points, more notably the claim by BBB and CCC that the family of appellant offered to settle the case. This,
however, was denied by Albina, who claimed that it was BBB and CCC who demanded P1,000,000.00.

The offer of compromise allegedly made by Albina is critical to the case at bar in light of law and
jurisprudence that an offer of compromise in a criminal case may be received in evidence as an implied
admission of guilt.

The accused testified that he had not asked his parents to plead the victim’s family for compromise,
instead they went there on their own.

ISSUE: w/n the act of the parents of the accused to compromise on their own will amounts to an implied
admission of guilt

RULING:
NO.

The alleged offer of the parents of appellant to settle the case cannot be used against appellant as
evidence of his guilt. Appellant testified that he did not ask his parents to settle the case. Moreover,
appellant was not present when the offer to settle was allegedly made.

An offer of compromise from an unauthorized person cannot amount to an admission of the party
himself. Although the Court has held in some cases that an attempt of the parents of the accused to
settle the case is an implied admission of guilt, we believe that the better rule is that for a compromise
to amount to an implied admission of guilt, the accused should have been present or at least authorized
the proposed compromise. Moreover, it has been held that where the accused was not present at the
time the offer for monetary consideration was made, such offer of compromise would not save the day
for the prosecution.

In addition, the Court, in weighing the evidence presented, may give less weight to the testimonies
of Albina, on the one hand, and BBB and CCC, on the other, as they are related to the appellant and the
victim, respectively. Their testimonies relating to the offer of settlement simply contradict each
other. As a matter of fact, even the lower courts did not consider the alleged offer of settlement in
resolving the case.

ACCUSED WAS ACQUITTED.

The friend of the victim, Joy, testified against her and claimed that the victim’s mother insist that she
change her statement to further impugn the accused.