G.R. Nos. 139698-726; February 20, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO D. MATUGAS, accused-appellant.

FACTS

This is an automatic review of the Regional Trial Court decision convicting Wilfredo Matugas of twenty-nine counts of rape against his daughter, Aime Matugas, and imposing the death penalty for each count. The prosecution alleged that from September 1995 to October 1997, accused-appellant, the victim’s father, repeatedly raped Aime in their Mandaue City home, often when her mother was away. Aime, who was 13 years old at the start of the abuse, testified in detail about the incidents, stating her father used force and threats to kill family members to ensure her silence. She finally reported the rapes to an aunt in October 1997. A medical examination revealed old, healed hymenal lacerations consistent with repeated sexual intercourse.
The defense presented an alibi, with accused-appellant claiming he was often away tending his farm. His wife, Librada Matugas, testified she never noticed anything amiss and suggested the charges were fabricated due to family disputes. Other defense witnesses attempted to impugn the complainant’s credibility and the plausibility of the repeated abuse without detection.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for twenty-nine counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of credibility, giving full weight to Aime’s candid, consistent, and unwavering testimony. The defense of alibi was properly rejected for being weak and unsubstantiated, especially as it failed to account for the numerous specific instances of abuse. The Court found no ill motive for the young complainant to falsely accuse her own father of a grave crime and endure the ordeal of a public trial. Her initial silence and delayed reporting were satisfactorily explained by the accused’s threats and her legitimate fear, which is common in cases of parental rape.
The medical findings, while negative for recent spermatozoa, corroborated her account of repeated sexual intercourse due to the presence of old hymenal lacerations. The totality of the evidence established moral certainty of the accused’s guilt. However, the Court modified the penalty. While the crimes qualified for the death penalty under Article 266-B for rape committed by a parent, the Supreme Court imposed reclusion perpetua for each count. This modification was due to the failure of the prosecution to prove with equal certitude the exact age of the victim at the time of each rape, as the amended complaints only alleged she was a “13-year-old girl” without specifying her precise age on each of the 29 different dates, a requisite for imposing the capital penalty. The Court also increased the civil indemnity and awarded moral and exemplary damages.