GR 131636; (March, 2003) (Digest)
G.R. No. 131636 ; March 5, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ARTEMIO INVENCION Y SORIANO, appellant.
FACTS
Artemio Invencion was charged with thirteen counts of rape against his 16-year-old daughter, Cynthia. After a consolidated trial, the Regional Trial Court convicted him in one case (Criminal Case No. 9375) and sentenced him to death, while acquitting him in the other twelve for insufficiency of evidence. The prosecution presented multiple witnesses. Cynthia’s half-brother, 8-year-old Elven, testified he was awakened by Cynthia’s cries and saw their father on top of her, making pumping motions. Neighbor Eddie Sicat testified he witnessed a similar act through a hole in the sawali wall of the house one morning. Medical examination confirmed Cynthia’s pregnancy and healed hymenal lacerations. Cynthia herself executed a sworn statement detailing the rape.
The defense did not present Artemio. Instead, his counsel testified that he visited the house and found it too dark to see inside, attempting to impeach Sicat’s testimony. On rebuttal, Gloria Pagala (Cynthia’s mother) and Celestino Navarro (the house owner) confirmed the existence of holes in the sawali walls during the relevant period, which were only repaired after Artemio’s arrest.
ISSUE
Whether the trial court erred in convicting Artemio Invencion of rape based on the credibility of the prosecution witnesses.
RULING
The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua, as the qualifying circumstance of the victim’s minority was not properly alleged in the information. The Court upheld the trial court’s assessment of witness credibility. It ruled that the testimony of the child witness, Elven, was admissible and credible. The Court found no improper coaching, noting that leading questions are allowed for child witnesses to elicit clear answers. His account was straightforward and consistent with human experience. The Court also found Eddie Sicat’s testimony credible. The defense’s claim that the house was too dark to see inside was successfully rebutted by evidence that holes existed in the walls at the time of the incident, allowing light and visibility. Sicat had no motive to falsely testify. The collective weight of the testimonies from Elven, Sicat, and the medical findings, corroborated by Cynthia’s own statement, established Artemio’s guilt beyond reasonable doubt. The award of damages was sustained, with civil indemnity set at P50,000.