GR 142901; (July, 2002) (Digest)
G.R. Nos. 142901-02; July 23, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JIMMY MANLOD, accused-appellant.
FACTS
The accused-appellant, Jimmy Manlod, was charged with two counts of qualified rape against his 14-year-old daughter, Jimmalou Manlod. The prosecution established that in June 1998, the first rape occurred one evening when Jimmalou was alone with her father in their home. After forcing her inside a bedroom, Manlod poked a double-bladed knife at her neck, threatened to kill her and her mother if she resisted, and proceeded to have carnal knowledge of her. A week later, the second rape transpired under similar circumstances in the morning, again with the use of a knife and threats. Jimmalou did not immediately report the incidents due to fear. The defense presented alibi and denial, claiming the charges were fabricated due to family discord.
ISSUE
The core issue for automatic review was whether the prosecution proved the guilt of the accused-appellant for two counts of qualified rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim-witness is paramount in rape cases. Jimmalou’s detailed, candid, and consistent testimony, delivered in a straightforward manner, was found credible and sufficient to establish the elements of rape. Her failure to shout or immediately report the crime was reasonable given the threats against her life and her mother’s life, coupled with the moral ascendancy and intimidation wielded by her father. The Court ruled that the defense of alibi and denial cannot prevail over the positive identification and credible testimony of the victim. The qualifying circumstances of minority and relationship were duly proven through Jimmalou’s birth certificate and testimonies, making the crimes qualified rape. Consequently, the penalty of death for each count was imposed, but in line with prevailing jurisprudence at the time, this was automatically reduced to reclusion perpetua due to the lack of the requisite number of concurring votes for its affirmation. The awards of civil indemnity, moral damages, and exemplary damages were also sustained.