G.R. No. 108771 June 21, 1994
The People of the Philippines, plaintiff-appellee, vs. Eduardo Benitez y Ventinilla, accused-appellant.

FACTS

The case involves the rape of Ramona Benitez by her natural father, accused-appellant Eduardo Benitez, from 1983 to 1989. The first abuse occurred in 1983 at their residence on Severino Street, Sta. Cruz, Manila, when Ramona was nine years old. The rapes continued even after the family moved to Baesa, Caloocan City. In one instance in June 1987, the accused-appellant used a knife to overcome Ramona’s resistance. He threatened her into silence. Ramona’s mother was nonchalant when informed, telling her to leave everything to God. Ramona finally reported the rapes on August 8, 1991, after accused-appellant left the conjugal dwelling in July 1989 to live with another woman. The trial court convicted accused-appellant of rape under Article 335 of the Revised Penal Code, sentencing him to reclusion perpetua and ordering him to indemnify Ramona. Accused-appellant denied the charges, claiming his job as a truck driver kept him away most of the time and that the complaint was motivated by his disapproval of Ramona’s live-in partner, Jerry Nunez. His wife, the victim’s mother, corroborated his denial as a hostile witness. The trial court found Ramona’s testimony credible and convicted accused-appellant.

ISSUE

Whether the trial court erred in convicting accused-appellant of rape based on the evidence presented.

RULING

The Supreme Court affirmed the trial court’s decision. It held that the conviction was based on the credible, categorical, and positive testimony of the victim, which satisfied the standard of proof beyond reasonable doubt. The Court rejected accused-appellant’s defenses: (1) His claim that he was only home on weekends and the absence of a house partition made rape impossible was negated by Ramona’s testimony that a rape in June 1987 occurred in the absence of her mother and brothers, and rape is not normally committed in front of witnesses. (2) The NBI finding of old-healed hymenal lacerations was not exculpatory, as it did not negate the commission of prior rape, regardless of any subsequent sexual activity with her live-in partner. (3) The victim’s continued residence in the same house and delay in reporting were understandable due to the accused-appellant’s threats, beatings, and his moral and physical influence as her father. No cogent motive for false accusation was shown. The penalty of reclusion perpetua and the award of indemnity were affirmed.