G.R. No. 130546 July 26, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON FLORES, accused-appellant.

FACTS

Accused-appellant Ramon Flores was charged with two counts of rape against his daughter, Marisol Flores, who was under twelve years old at the time of the incidents. The first charge (Criminal Case No. 3116) alleged rape committed in the first week of February 1994, while the second (Criminal Case No. 3117) pertained to an incident in the third week of December 1993. The prosecution’s evidence established that on both occasions, Marisol was awakened from sleep by her father, who used force, threat, and intimidation to have carnal knowledge of her. He also threatened to kill her and her family if she reported the assaults. Marisol initially kept silent out of fear but eventually disclosed the rapes to her mother after the accused abandoned the family. A medico-legal examination confirmed findings consistent with sexual abuse.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crimes of rape beyond reasonable doubt, particularly in light of the defense’s claim that the victim’s testimony was a mere concoction.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim is paramount. The testimony of the young victim, Marisol, was found to be credible, straightforward, and consistent. The Court noted that it is highly improbable for a child of tender years to fabricate a story of sexual abuse, especially one involving her own father, and to willingly undergo the ordeal of a public trial. Her delay in reporting the incidents was satisfactorily explained by the accused’s threats and the fear instilled in her, which is common in incestuous rape cases. The medical findings, though not conclusive of recent penetration, lent corroboration to her account.
Regarding the penalties, the Court modified the awards for damages. In Criminal Case No. 3116, qualified by the circumstance of the victim being under eighteen and the offender being a parent (a relationship constituting moral ascendancy under the law at the time), the death penalty was affirmed. The civil indemnity was increased to P75,000.00. In Criminal Case No. 3117, where the information did not allege the qualifying circumstance of relationship with specificity as required by prevailing jurisprudence at the time of the offense, the crime was treated as simple statutory rape, warranting reclusion perpetua with civil indemnity of P50,000.00. Moral damages of P50,000.00 were awarded in each case without need of further proof. The decision was affirmed with these modifications.