G.R. No. 174181
"x x x.
Petitioner also bemoans the fact that the dispositive portion of the trial court’s Decision did not expressly mention that he was found guilty beyond reasonable doubt of the crime charged. Suffice it to say, however, that a judgment is not rendered defective just because of the absence of a declaration of guilt beyond reasonable doubt in the dispositive portion. The ratio decidendi of the RTC Decision extensively discussed the guilt of the petitioner and no scintilla of doubt against the same was entertained by the courts below. Indeed, petitioner’s guilt was duly proven by evidence of the prosecution. In any event, a judgment of conviction, pursuant to Section 2, Rule 120 of the Rules of Court, is sufficient if it states: “1) the legal qualification of the offense constituted by the acts committed by the accused and the aggravating or mitigating circumstances which attended its commission; 2) the participation of the accused in the offense, whether as principal, accomplice or accessory; 3) the penalty imposed upon the accused; and 4) the civil liability or damages caused by his wrongful act or omission to be recovered from the accused by the offended party, if there is any, unless the enforcement of the civil liability by a separate civil action has been reserved or waived.” We find that all of these are sufficiently stated in the trial court’s Decision.
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