G.R. No. 187043 ; September 18, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. LORENZO OLIVA y ROSELA, Appellant.

FACTS

Appellant Lorenzo Oliva was convicted of two counts of qualified rape against his daughter, “M.” The first incident occurred in March 2003, when the 11-year-old victim was taken to a farm, ordered to undress under threat of a bolo, and sexually assaulted. The second incident happened on September 9, 2003, inside their home, where the appellant assaulted her while her sibling slept nearby, an act witnessed by her mother who subsequently reported it to the police. A medical examination confirmed old hymenal lacerations. The appellant denied the accusations, claiming he merely examined his daughter to determine if she had been molested by another relative and that he was asleep during the second alleged incident.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of Lorenzo Oliva for two counts of qualified rape.

RULING

The Supreme Court affirmed the conviction. The Court upheld the factual findings of the trial court, emphasizing that the victim’s credible and categorical testimony, corroborated by medical evidence, sufficiently established the crimes. The defense of denial and implausible alternative story were rejected, as mere denial cannot prevail over the positive identification and straightforward narration of a minor victim. The qualifying circumstances of minority and relationship were duly proven, warranting the penalty of reclusion perpetua for each count under Republic Act No. 9346 . The awards of damages were modified in accordance with prevailing jurisprudence, setting civil indemnity at ₱75,000, moral damages at ₱75,000, and exemplary damages at ₱30,000 for each count of rape.