GR 140218; (February, 2002) (Digest)
G.R. Nos. 140218-23; February 13, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS ESCAÑO, accused-appellant.
FACTS
Accused-appellant Carlos Escaño, the stepfather of the complainants, was charged with six counts of rape. The informations alleged that between March 1997 and February 1998, in Lingayen, Pangasinan, he sexually assaulted his stepdaughters, Mergie Raoet Macam and Zenaida Raoet Macam, both minors. The rapes were committed through force, intimidation, and the use of a bladed weapon. The cases were consolidated for trial. The prosecution presented the victims, who provided detailed testimonies of the assaults, describing how Escaño threatened them with a knife to ensure their submission and silence. Their mother was cohabiting with Escaño at the time. Medical examination supported Mergie’s claim of loss of virginity. The defense consisted of denial and alibi.
ISSUE
The core issue for automatic review is whether the guilt of accused-appellant Carlos Escaño for six counts of rape was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the testimonies of the victims, both young and of tender age, were credible, categorical, and consistent. The Court found no ill motive for them to falsely accuse their stepfather. Their detailed narrations, including the use of a weapon and specific threats, constituted proof of force and intimidation, which are essential elements of rape. The defense of denial and alibi was inherently weak and could not prevail over the positive identification by the victims. The relationship of stepfather-stepdaughter constituted moral ascendancy, which complemented the threats and facilitated the commission of the crimes. The medical finding of loss of virginity for Mergie corroborated her testimony. The Court, however, modified the penalties. While the death penalty was originally imposed, the Court ruled that the qualifying circumstance of relationship under Article 266-B must be specifically alleged in the information to warrant the supreme penalty. As the informations failed to allege that Escaño was the stepfather of the victims, a qualifying circumstance, the penalty was reduced to reclusion perpetua for each count. The awards of civil indemnity and moral damages were affirmed.