GR 140027; (March, 2002) (Digest)
G.R. No. 140027 March 18, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BIENVENIDO VALINDO, accused-appellant.
FACTS
The accused-appellant, Bienvenido Valindo, was charged with the rape of his seven-year-old stepdaughter, Jewelyn Abat, in Baliuag, Bulacan, in November 1997. The prosecution evidence established that Valindo, the live-in partner of the victim’s mother, undressed Jewelyn while she was caring for her siblings, threatened to kill her and her mother, and succeeded in having carnal knowledge of her. The victim’s candid testimony was corroborated by the medico-legal report of Dr. Manuel Aves, which indicated fresh healed lacerations consistent with recent penetration. The defense consisted of a denial and an alibi, claiming Valindo was working elsewhere during that period, a location merely a 30-minute ride away. The Regional Trial Court convicted Valindo of rape and imposed the death penalty.
ISSUE
The core issues for review were: (1) the sufficiency of the evidence to prove guilt beyond reasonable doubt, (2) the propriety of imposing the death penalty, and (3) the correctness of the awarded damages.
RULING
The Supreme Court affirmed the conviction but modified the penalty and damages. On the first issue, the Court upheld the trial court’s assessment of the victim’s credibility, noting that her straightforward testimony, especially given her tender age, bore the earmarks of truth and was strongly corroborated by physical evidence. Denial and alibi could not prevail over this positive identification. However, on the second issue, the Court reduced the penalty from death to reclusion perpetua. While the crime involved a stepdaughter, a circumstance warranting death under the law, the Information alleged the victim was a “stepdaughter,” whereas the evidence proved Valindo was merely the mother’s live-in partner, a relationship not legally equivalent to stepfather-stepdaughter. Following precedent in People v. Dimapilis, the death penalty could not be imposed when the relationship alleged differed from that proven. Finally, the Court modified the civil liability, awarding the victim P50,000.00 as civil indemnity and P50,000.00 as moral damages, in line with prevailing jurisprudence.