G.R. No. 130846 ; October 23, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGELIO PAMILAR y REVOLIO, accused-appellant.

FACTS

The accused-appellant, Rogelio Pamilar, was charged with three counts of rape against his daughters, Marivic and Cecilia Pamilar. Marivic testified that in March 1991 and again on October 13, 1992, her father, armed with a knife and using threats to kill her and her family, raped her while she slept. Cecilia testified that in October 1991, her father similarly raped her while she slept beside her sister. Both victims stated they did not immediately report the incidents due to fear, only doing so in October 1992. Dr. Susan Nieves, a medico-legal officer, confirmed both complainants were no longer virgins and had healed lacerations consistent with sexual intercourse.
The defense consisted of a denial. Rogelio Pamilar claimed the charges were fabricated by his wife, Corazon, out of anger because he had contracted a venereal disease. He asserted his daughters still loved him and were coerced by their mother. His son, Rogelio Jr., and wife testified to corroborate details about the house layout and his medical condition. The Regional Trial Court found the appellant guilty beyond reasonable doubt on all three counts and sentenced him to reclusion perpetua for each count, also awarding moral damages.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for three counts of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the victims, Marivic and Cecilia, to be credible, straightforward, and consistent. In rape cases, the credibility of the complainant is paramount, and the Court gives great weight to the trial court’s assessment, which observed the witnesses’ demeanor firsthand. The victims’ detailed accounts of the assaults, coupled with the medico-legal findings of healed lacerations, constituted strong evidence of carnal knowledge. The defense of denial and alleged instigation by the wife was inherently weak and could not prevail over the positive identification and categorical testimonies of the victims. The delay in reporting the rapes was sufficiently explained by their legitimate fear of their father, which is common in cases of intra-familial rape where the perpetrator exercises moral ascendancy and control. The Court modified the damages awarded, ordering the appellant to pay each victim P50,000 as civil indemnity, P50,000 as moral damages, and P25,000 as exemplary damages for each count, in line with prevailing jurisprudence. The penalties of reclusion perpetua for each count were affirmed.