G.R. No. 180499 ; July 9, 2008
THE PEOPLE OF THE PHILIPPINES, Appellee, vs. CONRADO CACAYAN, Appellant.

FACTS

Appellant Conrado Cacayan was charged with four counts of rape committed against his 18-year-old daughter, AAA. The incidents occurred on separate dates in May and June 1997. In each instance, appellant employed intimidation by threatening AAA with a bolo or knife, forcing her to submit to sexual intercourse. The rapes took place in isolated locations, such as a seashore, a mountain, a banana plantation, and a coconut grove, after appellant had sent away potential witnesses. AAA did not immediately report the assaults due to appellant’s death threats against her and her mother. She eventually confided in a friend, leading to a barangay report, a DSWD referral, and a police investigation. The medico-legal examination revealed healed hymenal lacerations consistent with multiple forcible penetrations.
Appellant denied the accusations, claiming AAA fabricated the charges because he had scolded and mauled her after learning she had a boyfriend. He asserted an alibi for some dates and argued that the charges were improbable. The Regional Trial Court convicted appellant of four counts of rape, sentencing him to reclusion perpetua for each count and awarding damages. The Court of Appeals affirmed the decision, prompting the appeal to the Supreme Court.

ISSUE

Whether the guilt of appellant for the crime of rape has been proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found AAA’s testimony to be credible, consistent, and convincing. She provided detailed accounts of each rape incident, describing the specific threats, locations, and her resistance. Her failure to report immediately was reasonably explained by her genuine fear of appellant, her father, who wielded moral and physical ascendancy over her. The medico-legal findings corroborated her claim of sexual assault. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The defense of denial and alibi was weak and unsubstantiated. Denial is inherently inferior to positive testimony, and alibi requires proof of physical impossibility to be at the crime scene, which appellant failed to establish. The Court found the relationship of father and daughter as an aggravating circumstance of relationship, which was properly considered. Applying the Indeterminate Sentence Law was correctly disallowed due to the imposition of reclusion perpetua. The awarded damages were modified in line with prevailing jurisprudence, granting civil indemnity, moral damages, and exemplary damages for each count of rape. The appealed decision was affirmed with modifications to the damages.