GR 137753; (March, 2001) (Digest)
G.R. Nos. 137753-56; March 16, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NILO ARDON, accused-appellant.
FACTS
The accused-appellant, Nilo Ardon, was charged with four counts of rape committed against his daughter, Jennilyn B. Ardon. Criminal Case No. 316 pertained to a rape committed in 1988 when Jennilyn was six years old. Criminal Cases Nos. 317, 318, and 319 involved three separate acts of qualified rape committed on October 11 and 12, 1994, when Jennilyn was twelve. The prosecution established that the sexual abuse began in 1988 and was repeated over the years, often when the victim’s mother was absent. Jennilyn testified in detail about the incidents, including the specific acts of penetration. Her initial reports to her mother were disbelieved until she disclosed the abuse to her uncle and grandmother in October 1994, leading to the filing of the cases.
The defense interposed denial and alibi, claiming the charges were fabricated due to family discord. The Regional Trial Court convicted Nilo Ardon, imposing reclusion perpetua for the 1988 rape and the death penalty for each of the three 1994 qualified rape charges. The case was elevated to the Supreme Court for automatic review.
ISSUE
The core issue is whether the guilt of the accused-appellant for the crimes of rape, particularly the qualified rapes warranting the death penalty, was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found Jennilyn’s testimony to be credible, consistent, and candid, satisfying the stringent standard of proof beyond reasonable doubt for rape cases. Her detailed account of the sexual assaults, including the specific dates in 1994, was deemed unshaken by cross-examination. The Court ruled that the defense of denial and alibi could not prevail over the positive and categorical identification by the victim. For the 1994 incidents, the qualifying circumstance of the victim being under eighteen and the offender being the parent was duly alleged and proven, warranting the imposition of the death penalty under Republic Act No. 7659 . The Court modified the awards for civil indemnity, moral, and exemplary damages in accordance with prevailing jurisprudence. The death sentences were affirmed subject to the review procedures for executive clemency.