GR 133586; (February, 2001) (Digest)
G.R. No. 133586 -603 February 19, 2001
People of the Philippines vs. Henry Queigan
FACTS
Accused-appellant Henry Queigan was charged with twenty-three counts of rape committed against his thirteen-year-old daughter, Angela Queigan, on various dates from June to August 1996, shortly after the death of her mother. The informations alleged he took advantage of his moral ascendancy and superior strength. Upon arraignment, he pleaded not guilty. The cases were consolidated for trial. The prosecution presented Angela’s detailed testimony, describing how her father initiated sexual assaults beginning June 30, 1996, and repeatedly raped her, often invoking that she should replace her deceased mother. Medical examination confirmed recent loss of virginity. The defense presented alibi and denial, claiming the charges were fabricated due to family disputes.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction but modified the penalties. The Court found Angela’s testimony credible, straightforward, and consistent. In rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi cannot prevail over the positive identification by the victim. The Court upheld the finding that the accused-appellant’s moral ascendancy as a father constituted sufficient intimidation, subverting the victim’s will. However, the Court modified the trial court’s decision. The death penalty was reduced to reclusion perpetua for each count because the informations failed to allege the victim’s exact age and her relationship to the accused with the requisite specificity needed for the imposition of the death penalty under Republic Act No. 7659 . The qualifying circumstances of minority and relationship must be expressly and precisely stated in the information to satisfy due process. The civil indemnity was also adjusted accordingly. The Court emphasized the heinous nature of incestuous rape but strictly applied the constitutional and procedural requirements for capital punishment.