GR 149893; (April, 2003) (Digest)
G.R. No. 149893 ; April 2, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MELCHOR RABAGO, accused-appellant.
FACTS
The prosecution established that on the evening of January 13, 1999, in their one-room house in Minglanilla, Cebu, appellant Melchor Rabago raped his 13-year-old daughter, Merliza. The victim testified that while she was sleeping, her father awakened her, covered her mouth, undressed her, and proceeded to have carnal knowledge of her against her will. She felt pain and noticed bleeding. After the act, appellant threatened her with a knife, warning her not to report the incident. The victim eventually disclosed the rape to her mother eight days later, leading to a medical examination which revealed a healed hymenal laceration.
The defense consisted solely of appellant’s denial. He claimed he was at home with his family that night and denied the accusation. The Regional Trial Court convicted appellant of rape qualified by the victim’s minority and her relationship to the offender, sentencing him to death and awarding damages.
ISSUE
Whether the trial court erred in convicting appellant of qualified rape based on the credibility of the victim’s testimony.
RULING
The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to the effectivity of Republic Act No. 9346 prohibiting the death penalty. The Court upheld the trial court’s assessment of the victim’s credibility, which it found to be sincere, straightforward, and consistent on material points. The Court emphasized that in rape cases, the trial court’s factual findings, especially on witness credibility, are accorded great respect. Minor inconsistencies, such as the exact time of the incident, do not undermine credibility but may even enhance it by showing unrehearsed testimony.
The legal logic rests on the principle that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The victim’s detailed account of the sexual assault, coupled with her emotional demeanor during testimony, was found credible and compelling. Her relationship to the appellant as his daughter and her minority at the time of the crime qualified the rape under Article 266-B of the Revised Penal Code, warranting the supreme penalty. Appellant’s bare denial could not prevail over the positive and categorical testimony of the victim. The medical findings, though indicating healed lacerations, were consistent with the victim’s account and the delay in reporting due to the father’s threats. Thus, the prosecution proved appellant’s guilt beyond reasonable doubt.