GR 224212; (November, 2019) (Digest)
G.R. No. 224212 , November 27, 2019
People of the Philippines, Plaintiff-Appellee, vs. Romeo De Castro De Guzman, Accused-Appellant.
FACTS
Accused-appellant Romeo De Castro De Guzman was charged with two counts of Qualified Rape in relation to Republic Act No. 7610 . The first incident allegedly occurred in 2003 when the victim, AAA, was around seven or eight years old. The second incident occurred on May 9, 2011, when AAA was fifteen years old. De Guzman is AAA’s stepfather, having cohabited with AAA’s mother after her separation from AAA’s biological father. AAA testified that in 2003, while her mother was out and her siblings were asleep, De Guzman called her to a small extension of their house, made her lie down, removed her shorts and underwear, and inserted his penis into her vagina. He warned her not to report the incident or make noise. On May 9, 2011, while AAA was sorting toys alone at home, De Guzman again approached her, removed her clothing, and had carnal knowledge with her. AAA did not shout due to fear. AAA eventually disclosed the rapes to her aunt in March 2011. A medical examination revealed healed hymenal lacerations consistent with penetrating trauma. De Guzman denied the accusations, claiming AAA was a problematic child who harbored ill feelings because he often scolded her. The Regional Trial Court convicted De Guzman of two counts of Qualified Rape, which the Court of Appeals affirmed with modifications to the penalties and damages.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant Romeo De Castro De Guzman for two counts of Qualified Rape.
RULING
The Supreme Court denied the appeal and affirmed the conviction with modifications. The Court held that all elements of Qualified Rape were proven beyond reasonable doubt. AAA’s testimony was credible, categorical, and consistent. The Court emphasized that in incestuous rape, the moral ascendancy of a stepfather substitutes for force or intimidation. AAA’s delay in reporting the rapes was justified by her youth, fear, and the accused’s threats. The medical findings of healed hymenal lacerations corroborated her testimony. The defense of denial could not prevail over AAA’s positive identification. The qualifying circumstance of the accused being the stepfather of the victim was duly alleged and proven. The Court modified the penalties and awarded civil indemnity, moral damages, and exemplary damages for each count of rape, with interest at the legal rate.