G.R. No. 93847 -48. November 14, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO TORREVILLAS Y ABALARAO, defendant-appellant.

FACTS

The appellant, Alberto Torrevillas, was convicted by the Regional Trial Court of two counts of rape against his stepdaughter, Evelyn Quinez. The incidents occurred on April 6 and May 4, 1988, at their residence in Caloocan City. On both occasions, Evelyn was alone with the appellant. He threatened her with a knife, used force and intimidation to subdue her, and had carnal knowledge against her will. Evelyn, who suffered from a physical disability due to polio, was unable to offer effective resistance. The crimes were revealed in September 1988 after Evelyn was found to be pregnant. She gave birth to a child in February 1989.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, particularly in light of the victim’s alleged failure to immediately report the incidents and the absence of physical injuries.

RULING

The Supreme Court affirmed the conviction. The Court held that the victim’s credible and categorical testimony, corroborated by her pregnancy and the birth of a child, sufficiently established the commission of rape. The defense of denial and alibi was rejected as inherently weak and could not prevail over the positive identification by the victim, who had no ill motive to falsely accuse her stepfather. The Court explained that the absence of physical injuries does not negate rape, as intimidation can be addressed to the mind, especially when a deadly weapon is used. The victim’s failure to immediately shout or report the assaults was reasonably explained by her physical disability, the direct threat with a knife, and the moral ascendancy and continuing threat posed by the appellant living in the same household. The delay in disclosure, under the circumstances of fear and intimidation, did not impair her credibility. The civil indemnity was increased to P30,000 for each count.