809 Robedillo, Art. 8, Sec. 14

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ARTICLE VII, SEC.

14 Judicial Department
Powers of the Supreme Court

PEOPLE v. LIZADA
G.R. NO. 143468, January 24, 2003

POINT OF THE CASE: No decision shall be rendered by any court without expressing therein
the facts and the law on which it is based.

FACTS OF THE CASE: Freddie Lizada was charged with four counts of qualified rape by his
stepdaughter, Analia Orillosa by embracing, kissing, and touching her private parts and then proceeded
with carnal knowledge to remove her skirt and panty and placed himself on top of her and tried to insert
his penis into her vagina.
But the medical examination revealed that Analia’s hymen was intact, and the other parts of her
vagina was not injured due to an insertion of average-sized adult Filipino male organ in full erection. The
testimony of Analia’s sister is also affirmative to the result of the medico legal and said that Lizada did not
insert his penis because he stopped when he saw her.
RTC accused guilty beyond reasonable doubt of the crime charged against him and sentenced to
Death Penalty in each and every case. However, Lizada opposed the sentence and claimed that the
prosecution failed to prove his guilt beyond reasonable doubt and that the testimony of Analia’s sister was
not taken into consideration in the decision.

ISSUE: Whether or not Freddie Lizada is guilty of qualified rape


RULING: No. The Regional trial court failed to comply with the requirements under the Constitution
and the Rules of Criminal Procedure and failed to specifically state the facts proven by the prosecution.
Furthermore, it did not also specify the factual and legal bases for its imposition of the supreme penalty of
death on accused-appellant. As reference to the Section 14, Article 8 of the Constitution, no decision shall
be rendered by any court without expressing therein the facts and the law on which it is based.
And that due to insufficient weight of evidence, the Court ruled that Lizada is guilty only of two
counts of simple rape instead of qualified rape to which the penalty is only reclusion perpetua.

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