The Supreme Court of Guam reversed the criminal sexual conduct convictions of William Robert Reyes and granted him a new trial, finding the trial court committed reversible error during his prosecution. The decision, issued as *People of Guam v. William Robert Reyes* (2025 Guam 8), addressed Reyes's appeal from his convictions of first and second degree criminal sexual conduct.
The case stems from Superior Court Case No. CF0747-23, where Reyes was convicted on both charges following a jury trial. Reyes appealed his convictions to the Supreme Court of Guam under Case No. CRA24-013, challenging two key rulings by the trial court that he argued prejudiced his defense.
The central issue on appeal involved the trial court's handling of cross-examination evidence. During trial, Reyes moved for a mistrial after the People of Guam was permitted to cross-examine him about a prior arrest and indictment involving alleged crimes against three girls from over 20 years ago. The prosecution's questioning about these decades-old allegations occurred despite Reyes's objection to this line of inquiry.
Chief Justice Robert J. Torres, writing for the court, found that the trial court abused its discretion in denying Reyes's motion for a mistrial. The opinion noted that after overruling Reyes's objection to the questioning about the prior arrest, the trial court denied the mistrial motion based on what the Supreme Court characterized as "an inapplicable rule of evidence, without performing any analysis under any relevant rule of evidence."
This procedural error proved fatal to the prosecution's case. The Supreme Court determined that allowing the jury to hear about allegations from more than two decades ago, without proper legal foundation or analysis, created unfair prejudice against Reyes that could not be cured through jury instructions or other remedial measures.
Reyes also challenged the trial court's denial of his motion for a judgment of acquittal on the first-degree criminal sexual conduct charge. While the Supreme Court opinion excerpt does not detail the resolution of this issue, it formed part of his comprehensive challenge to the convictions.
The case was argued and submitted before the Supreme Court on Feb. 25, 2025, in Hagåtña, Guam. The three-justice panel included Chief Justice Robert J. Torres, Associate Justice F. Philip Carbullido, and Associate Justice Katherine A. Maraman. All three justices participated in the decision.
Heather M. Quitugua of the Law Offices of Heather Martinez Quitugua represented Reyes on appeal. The defense attorney's office is located in Hagåtña, highlighting the local legal community's involvement in this territorial Supreme Court matter.
The People of Guam was represented by Nathan M. Tennyson, identified in court records as a former Acting Deputy Attorney General from the Office of the Attorney General's Appellate & Writing Division. The prosecution team operated from offices in Tamuning, demonstrating the territorial government's commitment to appellate advocacy in criminal matters.
The ruling represents a significant victory for criminal defendants' rights in Guam's territorial jurisdiction. By finding the trial court's evidentiary ruling constituted reversible error, the Supreme Court reinforced important protections against prejudicial evidence that lacks proper legal foundation.
The decision also highlights the importance of proper evidentiary analysis in criminal trials. Courts must carefully weigh the probative value of evidence against its potential for unfair prejudice, particularly when dealing with allegations from remote time periods that may have limited relevance to current charges.
For the prosecution, the ruling means starting over with a new trial. The People of Guam will need to proceed without the prejudicial cross-examination that derailed the first trial, potentially making their case more challenging to prove beyond a reasonable doubt.
The case demonstrates how appellate courts serve as crucial safeguards for ensuring fair trials in the criminal justice system. When trial courts make legal errors that affect fundamental fairness, appellate review provides essential correction mechanisms to protect defendants' constitutional rights.
This decision will likely influence how Guam's trial courts handle similar evidentiary questions in future criminal cases, particularly regarding the admissibility of remote prior bad acts or arrests that lack direct relevance to pending charges.
The new trial will provide both parties a fresh opportunity to present their cases under proper evidentiary standards, ensuring that any verdict reflects a fair adjudication of the actual charges rather than prejudicial information that should not have been considered by the jury.