GR 175317; (October, 2009) (Digest)
G.R. No. 175317 ; October 2, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CRISTINO CAÑADA, Accused-Appellant.
FACTS
The prosecution charged appellant Cristino Cañada, the stepfather of the 15-year-old victim AAA, with rape. The Information alleged that on November 28, 1998, in Lantawan, Basilan, the accused, armed with a scythe, entered the toilet where AAA was answering the call of nature. Through force and intimidation, he grabbed her, threatened her, removed her clothing, and had carnal knowledge against her will, causing physical injuries. AAA testified that the appellant pushed her, pointed a scythe at her neck, and raped her. Her mother, BBB, testified she saw the appellant block AAA’s path and push her toward the toilet wall. AAA reported the rape to her mother days later, leading to a medical examination which confirmed fresh lacerations consistent with sexual assault.
The defense presented a denial and alibi. The appellant claimed he was elsewhere gathering tuba (coconut wine) at the time of the alleged incident. His mother corroborated his alibi. The defense argued that the charge was fabricated due to family resentment.
ISSUE
Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found AAA’s testimony to be credible, straightforward, and consistent. The defense of denial and alibi cannot prevail over the positive identification by the victim. The medical findings of lacerations on AAA’s labia majora and posterior fourchette, which the examining physician testified could have been caused by a hard object like a penis, corroborated her account of a recent sexual assault. The Court also found the delay in reporting the incident justified, as it was due to AAA’s reasonable fear of the appellant, her stepfather, who had threatened to kill her and her mother. The relationship of ascendancy and moral authority of a stepfather further bolstered the credibility of the victim’s claim of intimidation. The elements of rape through force or intimidation were thus sufficiently established. The penalty of reclusion perpetua was affirmed, with the award of civil indemnity, moral damages, and exemplary damages modified in accordance with prevailing jurisprudence.