G.R. No. 183827 ; November 12, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ENERIO ENDING y ONYONG, Accused-Appellant.

FACTS

The accused-appellant, Enerio Ending, was charged with three counts of incestuous rape against his then 15-year-old daughter, AAA. The prosecution’s evidence established that the rapes occurred on three separate occasions: on January 18, 2000, inside their home; in the fourth week of January 2000, at a copra drier; and on January 2, 2001, in a banana plantation. AAA testified that her father used force, intimidation, and threats, including brandishing a bolo and threatening to kill her and her mother if she reported the assaults. She eventually disclosed the incidents to a classmate and a teacher, leading to a police report and a medical examination that confirmed old lacerations consistent with sexual intercourse.
The defense, consisting solely of the appellant’s testimony, denied the accusations. He claimed that AAA was living with her grandparents during the alleged incidents and suggested that her motive for filing the charges was resentment stemming from his earlier reprimand and physical punishment for having a boyfriend. He asserted he could think of no reason why his daughter would accuse him falsely.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for three counts of rape beyond reasonable doubt, hinging on the credibility of the witnesses.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the case rested fundamentally on credibility, and the consistent findings of both the trial court and the Court of Appeals on the credibility of the victim are accorded great weight and respect. The Court found no reason to deviate from these findings, as there was no showing that the lower courts overlooked or misappreciated facts that would alter the case’s outcome.
The Court found AAA’s testimony to be credible, straightforward, and consistent. Her detailed account of the successive assaults, coupled with her explanation for the delayed disclosure—fear due to her father’s threats—was deemed natural and convincing for a young victim. The medical certificate corroborated her claim of sexual abuse. In contrast, the appellant’s denial and imputation of ill motive were deemed weak defenses that could not prevail over the positive and categorical testimony of the victim. The qualifying circumstance of relationship (father-daughter) was duly proven, warranting the imposition of reclusion perpetua for each count without eligibility for parole, in lieu of the death penalty following Republic Act No. 9346 . The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages.