DEFINITION AND FORM OF JUDGMENTS:
action has been reserved or waived. The purpose of
1. PEOPLE vs LIZADA, January 24, 2003
FACTS: Acused-appellant was charged with four
counts of qualified rape under four separate
Informations. RTC rendered accused guilty beyond
reasonable doubt of the crime charged against him
and sentenced to Death Penalty in each and every
case as provided for in the seventh paragraph, no. 1,
Article 335 of the Revised Penal Code. However,
petitioner averred in his brief that the prosecution
failed to prove his guilt beyond reasonable doubt and
that the testimony of Rossel, one of the witnesses,
was not taken into consideration in the decision.
ISSUE: Did the trial court err in not making a finding
of fact in its decision by merely summarizing the
testimonies of the witnesses of the prosecution and
those of accused-appellant and his witnesses, and
forthwith set forth the decretal portion of said portion
RULING: YES. Article VIII, paragraph 14 of the 1987
Constitution provides that no decision shall be
rendered by any court without expressing therein
clearly and distinctly the facts and the law on which it
is based. This requirement is reiterated and
implemented by Rule 120, Section 2 of the 1985
Rules on Criminal Procedure, as amended, which
reads: The judgment must be written in the official
language, personally and directly prepared by the
judge and signed by him and shall contain clearly and
distinctly a statement of the facts proved or admitted
by the accused and the law upon which the judgment
is based. If it is of conviction, the judgment shall state
(a) the legal qualification of the offense constituted by
the acts committed by the accused, and the
aggravating or mitigating circumstances attending the
commission thereof, if there are any; (b) the
participation of the accused in the commission of the
offense, whether as principal, accomplice, or
accessory after the fact; (c) the penalty imposed upon
the accused; and (d) the civil liability or damages
caused by the wrongful act to be recovered from the
accused by the offended party, if there is any, unless
the enforcement of the civil liability by a separate
the provision is to inform the parties and the person
reading the decision on how it was reached by the
court after consideration of the evidence of the parties
and the relevant facts, of the opinion it has formed on
the issues, and of the applicable laws. The parties
must be assured from a reading of the decision of the
trial court that they were accorded their rights to be
heard by an impartial and responsible judge. More
substantial reasons for the requirement are: For one
thing, the losing party must be given an opportunity to
analyze the decision so that, if permitted, he may
elevate what he may consider its errors for review by
a higher tribunal. For another, the decision if well-
presented and reasoned, may convince the losing
party of its merits and persuade it to accept the
verdict in good grace instead of prolonging the
litigation with a useless appeal. A third reason is that
decisions with a full exposition of the facts and the
law on which they are based, especially those coming
from the Supreme Court, will constitute a valuable
body of case law that can serve as useful references
and even as precedents in the resolution of future
controversies. The trial court is mandated to set out in
its decision the facts which had been proved and its
conclusions culled therefrom, as well as its resolution
on the issues and the factual and legal basis for its
resolution. Trial courts should not merely reproduce
the respective testimonies of witnesses of both
parties and come out with its decretal conclusion. In
this case, the trial court failed to comply with the
requirements under the Constitution and the Rules on
Criminal Procedure. It merely summarized the
testimonies of the witnesses of the prosecution and of
accused-appellant on direct and cross examinations
and merely made referral to the documentary
evidence of the parties then concluded that, on the
basis of the evidence of the prosecution, accused-
appellant is guilty of four counts of rape and
sentenced him to death, on each count. The trial court
even failed to specifically state the facts proven by the
prosecution based on their evidence, the issues
raised by the parties and its resolution of the factual
and legal issues, as well as the legal and factual
bases for convicting accused-appellant of each of the
crimes charged. The trial court rendered judgment
against accused-appellant with the curt declaration in
the decretal portion of its decision that it did so based
on the evidence of the prosecution.