G.R. No. 117092 October 6, 1995
People of the Philippines, plaintiff-appellee, vs. Mario Lao y Clarin, accused-appellant.

FACTS

The case involves the incestuous rape of fourteen-year-old Cherry Lao by her father, accused-appellant Mario Lao, on May 19, 1992, in Paniqui, Tarlac. Cherry testified that her father ordered her siblings out of their house, closed the doors and windows, and proceeded to kiss her, undress her, and sexually assault her despite her resistance and pleas. She managed to push him away, saw him masturbating, and fled. The victim reported the incident to the police the next day and underwent a medical examination, which revealed a healed laceration consistent with sexual intercourse.
At trial, the prosecution presented Cherry’s consistent and credible testimony, corroborated by her mother and grandmother. The defense presented the accused, who denied the charges and claimed the complaint was fabricated due to a family dispute over land. The trial court convicted Mario Lao of rape and sentenced him to reclusion perpetua, ordering him to pay moral and exemplary damages. The accused appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant is paramount in rape cases, especially when the accused is a close relative. Cherry’s testimony was found to be clear, convincing, and consistent, delivered with sincerity and emotion. The Court noted that her detailed account of the assault, including her resistance and the accused’s subsequent act of masturbation, bore the hallmarks of truth. Her immediate reporting of the crime and the medical findings, while not showing fresh injuries, corroborated her claim of prior sexual abuse and were consistent with her testimony.
The Court rejected the defense of denial and alibi, which were inherently weak against the positive identification by the victim. It also found the motive of land dispute insufficient to explain why a young daughter would fabricate a grave charge of incestuous rape, publicly subjecting herself to stigma. The trial court’s assessment of witness credibility was accorded great respect. The award of moral and exemplary damages was upheld to provide solace to the victim and to serve as a deterrent. The penalty of reclusion perpetua was affirmed, being the proper penalty for rape at the time of the commission of the crime.