G.R. No. 189836; June 5, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROMEO BUSTAMANTE y ALIGANGA, Accused-Appellant.

FACTS

The accused-appellant, Romeo Bustamante y Aliganga, was charged with the rape of his daughter, AAA. The Information alleged that on or about February 17, 1997, and prior thereto, in Alcala, Cagayan, the appellant, through threat and intimidation, had sexual intercourse with his daughter against her will, starting from when she was eleven years old. The offense was committed before the effectivity of Republic Act No. 8353 (the Anti-Rape Law of 1997).
During trial, AAA testified that on February 17, 1997, around lunchtime, she was alone on the second floor of their house when the appellant arrived. He laid her down, removed her shorts and panty, removed his pants, went on top of her, inserted his penis into her vagina, and ejaculated. He then threatened her not to report the incident. She did not shout due to fear. She later reported the incident to her mother and the police. She filed the case because the appellant raped her and to stop him from maltreating her.
The defense presented a different version. Appellant testified that on February 17, 1997, he and AAA went to Tuguegarao to seek advice from Sgt. Poli and his employer, Lolita Casauay, regarding AAA having been molested by her cousin, Randy Torrado. Sgt. Poli advised him to report the matter to the Alcala Police. Upon returning home that evening, he was mauled and tied up by his brothers-in-law (Rogelio and Amador Torrado) and Purita Torrado, after which policemen arrived and brought him to the municipal hall without explanation. He claimed the rape charge was fabricated by his wife and in-laws because they harbored ill feelings against him for allegedly spreading a rumor that Rogelio Torrado fathered Purita Torrado’s child. Defense witnesses Sgt. Poli and Lolita Casauay corroborated that appellant and AAA approached them on February 17, 1997, regarding AAA being molested by her cousin, and that they advised reporting it to the police.
The Regional Trial Court found the appellant guilty beyond reasonable doubt of rape under Article 335 of the Revised Penal Code and sentenced him to reclusion perpetua, ordering him to pay AAA ₱75,000.00 as civil indemnity, ₱50,000.00 as moral damages, and ₱30,000.00 as exemplary damages. The Court of Appeals affirmed the trial court’s decision in toto.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of the accused-appellant for the crime of rape, specifically concerning: (1) the credibility of the private complainant’s testimony, and (2) the sufficiency of the prosecution’s evidence to prove guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals.
The Court held that the appeal was without merit. It reiterated settled jurisprudence that in rape cases, the accused may be convicted solely on the basis of the victim’s testimony if it is credible, convincing, and consistent with human nature and the normal course of things. The trial court’s assessment of the witnesses’ credibility is accorded great weight and respect, as it had the direct opportunity to observe their demeanor and conduct.
The Court found AAA’s testimony to be clear, straightforward, and credible. Her account of the rape incident was consistent and detailed. The fact that she did not shout during the assault was reasonable given her fear of the appellant, who was her father and had threatened her. Her motive for filing the case—because she was raped and to stop the appellant’s maltreatment—was deemed natural and justified.
The defense’s theory of fabrication was rejected. The Court found the defense’s narrative—that the charge was motivated by the family’s ill will over a rumor—insufficient to overcome the positive and credible testimony of the victim. The defense witnesses’ accounts regarding the report of AAA’s molestation by her cousin did not disprove the occurrence of the rape by the appellant. The Court emphasized that the evidence for the prosecution established the appellant’s guilt beyond reasonable doubt.
The penalty of reclusion perpetua was affirmed. Following prevailing jurisprudence, the Court also modified the damages awarded, increasing the civil indemnity and moral damages to ₱75,000.00 each and exemplary damages to ₱30,000.00. All damages were to earn interest at the legal rate of six percent (6%) per annum from the date of finality of the judgment.