G.R. Nos. 150523-25 ; July 2, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ONOFRE GALANG Y MENDOZA, appellant.

FACTS

Onofre Galang y Mendoza, the common-law husband of Loida Pacampara, was convicted for three counts of rape against Loida’s daughter, Edlyn. The charges stemmed from incidents in March 1997, March 28, 1999, and April 2, 1999. Edlyn testified that Galang, whom she considered her stepfather, sexually assaulted her on these dates, using threats against her family to secure compliance. The rape on March 28, 1999, was discovered by Loida, who later reported the crimes. Galang denied the accusations, claiming the complaints were fabrications motivated by Loida’s jealousy over his closeness to Edlyn and that the alleged incidents could not have occurred as they were never alone together.

ISSUE

The core issue is whether the prosecution proved Galang’s guilt for the crimes of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions for the rapes committed on March 28 and April 2, 1999, but acquitted Galang for the March 1997 incident due to insufficient evidence. The Court found Edlyn’s testimony for the 1999 incidents credible, natural, and consistent. Her detailed account, coupled with her emotional demeanor during trial, lent veracity to her charges. The defense of denial and alibi was weak and uncorroborated. The Court ruled that the qualifying circumstance of relationship was present under Article 266-B of the Revised Penal Code, as amended by R.A. 8353, since Galang was the common-law spouse of the victim’s mother. This qualified the rapes and warranted the imposition of the death penalty for the two 1999 cases. The Court also awarded civil indemnity of P75,000.00 and moral damages of P50,000.00 for each of the two affirmed convictions. The records were ordered forwarded for possible executive clemency as required by law.