G.R. No. 133434 ; March 21, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BERNABE E. ADILA, JR., accused-appellant.

FACTS

The case involves the statutory rape of an eleven-year-old girl, Sheila C. Baco, by her stepfather, Bernabe Adila, Jr., on the night of December 25, 1994, in Sindangan, Zamboanga del Norte. Sheila testified that while her mother was away for a medical check-up, she was asleep with her younger siblings when the accused, who had returned from a benefit dance, awakened her. He then forcibly removed her clothing, pinned her down, covered her mouth, and had carnal knowledge of her against her will, causing her pain and bleeding. After the act, the accused asked for forgiveness but threatened to kill her and her mother if she disclosed the incident. Sheila eventually reported the rape to her aunt in January 1995, leading to a medical examination which confirmed recent hymenal lacerations consistent with sexual intercourse.
The defense presented denial and alibi. Accused-appellant, supported by the testimony of his wife (the victim’s mother), Loida Adila, claimed he was in Sindangan attending to his recuperating wife from December 23 to 30, 1994, and thus could not have been at the scene of the crime. Loida also testified that Sheila initially could not identify her assailant. The Regional Trial Court convicted Adila of statutory rape and, due to the qualifying circumstance of the victim being under eighteen and the offender being a step-parent, imposed the death penalty and ordered P50,000.00 in civil indemnity.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of statutory rape beyond reasonable doubt, thereby warranting the imposition of the death penalty.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court found the victim’s testimony to be clear, credible, and consistent, detailing the traumatic event in a manner that bore the hallmarks of truth. The medical findings corroborated her account. The defense of alibi and denial was rejected as inherently weak and insufficient to overcome the positive identification by the victim, especially given that the accused did not demonstrate it was physically impossible for him to be at the crime scene. The Court emphasized that in rape cases, the testimony of a young victim, when credible, is sufficient to sustain a conviction.
The crime constituted statutory rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353 , as the victim was under twelve years old at the time. The presence of the qualifying circumstance under Article 266-B—that the victim was under eighteen and the offender was a step-parent—mandated the imposition of the death penalty, as this relationship constitutes a special aggravating circumstance. The Court modified the civil liability, increasing the indemnity to P75,000.00 and awarding an additional P50,000.00 as moral damages, in line with prevailing jurisprudence for cases where the death penalty is imposed. The records were ordered transmitted to the Office of the President for possible executive clemency.