GR 112164; (February, 1996) (Digest)
G.R. Nos. 112164-65; February 28, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SOLOMON VILLANUEVA Y ODE, accused-appellant.
FACTS
The accused-appellant, Solomon Villanueva, was charged with two counts of rape committed against his daughter, Lea, who was 12 years old at the time of the first incident in September 1990. Lea testified that her father initiated sexual intercourse with her, threatening to kill her and her family if she reported it. This abuse allegedly occurred around four times a week for nearly two years. The second specific charge was for an incident on June 14, 1992. Lea reported the rapes to her grandmother after her mother’s death in June 1992. A medical examination confirmed old-healed lacerations on her hymen. The accused initially denied the charges, presenting an alibi that he was at work during the alleged times. The trial court convicted him of two counts of rape and sentenced him to reclusion perpetua for each count.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt, particularly in light of his defenses of alibi, alleged consent, and challenges to the credibility of the victim’s testimony.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Lea’s testimony as categorical, positive, and convincing. It rejected the accused’s defenses as baseless. The claim of consent was deemed appalling and legally untenable, as a 12-year-old cannot give meaningful consent, and the father’s moral ascendancy and threats vitiated any possible volition. The alibi was weak for failing to prove it was physically impossible for him to be at the crime scene. The Court emphasized that the victim’s delay in reporting, explained by continuous threats and fear, does not undermine credibility but is typical in incestuous rape cases. The medical findings corroborated her account. Regarding penalties, the Court affirmed the indivisible penalty of reclusion perpetua for each count, clarifying that it has no periods. The civil liability was modified, ordering the accused to pay P50,000.00 as civil indemnity and P25,000.00 as exemplary damages for each count, totaling P150,000.00, to serve as a deterrent.