G.R. No. 218427 . January 31, 2018.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. EMILIANO DE CHAVEZ, Accused-Appellant.

FACTS

The accused-appellant, Emiliano De Chavez, was charged with two counts of rape by sexual assault and two counts of qualified rape against his 13-year-old daughter, AAA. The incidents occurred in June and September 2005 in Laguna. For the sexual assault charges, it was alleged that he inserted his finger into AAA’s genitalia. For the qualified rape charges, it was alleged that he had carnal knowledge of her. The prosecution presented AAA’s detailed testimony, corroborated by her sister who witnessed one incident, and the medico-legal report which showed deep, healed hymenal lacerations consistent with sexual abuse. The appellant denied the accusations, claiming they were fabricated in retaliation for his disciplinary actions against his children.
The Regional Trial Court convicted De Chavez on all counts. The Court of Appeals affirmed the convictions but modified the penalties and awarded damages. The appellant then elevated the case to the Supreme Court, arguing that the testimony of the victim was not credible and that the evidence was insufficient to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape by sexual assault and two counts of qualified rape.

RULING

The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim’s testimony, which was clear, candid, and consistent, was not impaired by minor inconsistencies. The Court ruled that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The medico-legal findings, which showed deep, healed lacerations, corroborated her account of sexual intercourse. The Court also found the qualifying circumstance of relationship duly proven, as the appellant is the father of the victim, warranting the imposition of the death penalty were it not for the prohibition under Republic Act No. 9346 . Instead, the penalty of reclusion perpetua without eligibility for parole was correctly imposed for the qualified rape charges. The awards of civil indemnity, moral damages, and exemplary damages were sustained in accordance with prevailing jurisprudence. The defense of denial and frame-up, being inherently weak, could not prevail over the positive and credible testimony of the victim.