G.R. No. 218913 , February 7, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ROMULO BANDOQUILLO y OPALDA, Accused-Appellant

FACTS

The accused-appellant, Romulo Bandoquillo, was charged with the rape of his 14-year-old daughter, AAA, on December 27, 2003. The prosecution alleged that in the early morning, while AAA was sleeping in their house in Irosin, Sorsogon, Bandoquillo forcibly undressed her, touched her breasts, and had carnal knowledge of her against her will and despite her pleas. AAA immediately reported the incident to her mother, and a medical examination later revealed healed lacerations and hematoma in her vaginal area, corroborating her account.
The defense presented a different narrative, with Bandoquillo testifying as the lone witness. He claimed that on the evening before the alleged incident, he discovered a man fleeing from his house and, upon confronting AAA, he slapped her for her evasive answers. He denied committing rape and suggested that AAA fabricated the charge because of this disciplinary action.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction for Qualified Rape. The Court upheld the findings of the lower courts, giving great weight to the credibility of AAA’s testimony. It found her narration of the incident to be clear, consistent, and candid, delivered in a manner typical of a child victim. The medical findings of healed lacerations provided physical corroboration of sexual intercourse. The Court emphasized that for rape to be consummated, full penetration is not required; proof of the entrance of the male organ into the labia of the female organ suffices, which AAA consistently attested to.
The Court categorically rejected the defense of denial and alibi. It ruled that mere denial cannot prevail over the positive, categorical, and credible testimony of the victim. The appellant’s claim that AAA fabricated the charge due to being slapped was deemed insufficient motive for a daughter to accuse her own father of a grave crime that would bring shame to the entire family. The Court noted the absence of any evidence showing an ill motive for AAA to falsely testify. Furthermore, the qualifying circumstances of minority (AAA was 14 years old) and relationship (the offender is the father of the victim) were duly proven and admitted, warranting the classification as Qualified Rape under Article 266-B of the Revised Penal Code. Consequently, the penalty of reclusion perpetua without eligibility for parole was affirmed. The Court also modified the damages, awarding civil indemnity, moral damages, and exemplary damages in the amount of ₱100,000.00 each, with interest at 6% per annum from finality until fully paid.