G.R. No. 199210 ; October 23, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RICARDO M. VIDAÑA, Accused-Appellant.

FACTS

The accused-appellant, Ricardo M. Vidaña, was charged with the rape of his 15-year-old daughter, AAA, in relation to Republic Act No. 7610 . The prosecution alleged that on September 16, 2003, in their one-bedroom house, Vidaña, while alone with his sleeping children, pulled AAA from the bedroom to the sala. He covered her mouth, forcibly undressed her, and had carnal knowledge against her will, threatening to kill her and her siblings if she reported the incident. The next day, AAA disclosed the rape to a family friend, who accompanied her to the police. A medico-legal examination revealed a positive healed hymenal laceration.
The defense presented a denial and alibi. Vidaña claimed AAA was living with the Joaquin family since August 2003 and was not in his house on the alleged date. He asserted he was harvesting in the fields with his common-law wife during the time of the incident, a claim corroborated by his son, EEE. The defense also challenged AAA’s credibility, arguing her testimony lacked details of physical resistance.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of the accused-appellant for rape in relation to R.A. No. 7610 .

RULING

The Supreme Court affirmed the conviction with modifications. The Court found the appeal devoid of merit, upholding the factual findings and credibility assessments of the lower courts. It ruled that the victim’s categorical, consistent, and straightforward testimony, corroborated by medical findings, was sufficient to establish guilt beyond reasonable doubt. The Court emphasized that in rape cases, the victim’s testimony, if credible, is enough to sustain a conviction.
The defense of denial and alibi was rejected as inherently weak and could not prevail over the positive identification by the victim. The Court also noted that failure to offer tenacious physical resistance is immaterial when intimidation is exercised, as in this case where the accused used his moral ascendancy as a father and issued death threats. The crime was properly qualified as rape under Article 266-A of the Revised Penal Code in relation to Section 5(b) of R.A. No. 7610 . The penalty was modified to reclusion perpetua without eligibility for parole. Awards for civil indemnity, moral damages, and exemplary damages were increased in line with prevailing jurisprudence.