G.R. No. 82223 -24 November 13, 1992
People of the Philippines, plaintiff-appellee, vs. Manuel Matrimonio y Padilla, accused-appellant.

FACTS

Rowena Matrimonio, a 14-year-old girl, was sexually assaulted twice by her natural father, the appellant Manuel Matrimonio, in their home in Sampaloc, Manila. The first rape occurred on December 27, 1985, resulting in her pregnancy. The second rape occurred on April 5, 1986. On both occasions, the appellant threatened to kill Rowena, her mother, and her siblings if she did not yield. Rowena reported the incidents on June 25, 1986, after confiding in her mother. A medico-legal examination confirmed her pregnancy and physical findings consistent with sexual intercourse. Two complaints for rape were filed. The appellant admitted sexual intercourse but claimed Rowena voluntarily offered herself and they lived as husband and wife for about a year, also alleging he was not her biological father. The trial court consolidated the cases and found the appellant guilty of two counts of rape, sentencing him to reclusion perpetua for each count.

ISSUE

The core issue is whether the appellant is guilty beyond reasonable doubt of the crime of rape for both incidents.

RULING

The Supreme Court affirmed the trial court’s decision, finding the appellant guilty of two counts of rape. The Court held that Rowena’s testimony was credible, straightforward, and consistent. Her delay in reporting the crimes was sufficiently explained by the appellant’s threats against her and her family. The medico-legal findings corroborated her account. The appellant’s defenses of consent and alleged non-paternity were rejected. The claim of a consensual relationship was deemed inherently incredible given the father-daughter relationship and Rowena’s age and fear. The Court emphasized that in rape cases, the accused may be convicted solely on the credible testimony of the victim. The penalties of reclusion perpetua for each count were upheld.