GR 114387; (March, 1997) (Digest)
G.R. No. 114387 March 14, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO DEVILLERES, accused-appellant.
FACTS
Accused-appellant Alejandro Devilleres was charged with the rape of his 15-year-old daughter, Lorena Devilleres. The prosecution alleged that on April 18, 1991, at dawn in Malabuyoc, Cebu, while his wife was away fetching water, Alejandro used a gaff to threaten Lorena, removed her clothing, and had carnal knowledge of her against her will. Lorena testified to the specific details of the assault, her subsequent flight from home, and her report to her mother. Medical examination by Dr. Luz Soria confirmed healed hymenal lacerations consistent with sexual intercourse.
The defense consisted solely of Alejandro’s testimony, denying the rape and claiming that Lorena fabricated the charge to retaliate for previous physical punishments he had inflicted on her. He asserted an alibi, stating he was at his father’s house at the time of the alleged incident. The Regional Trial Court convicted Alejandro of rape and sentenced him to reclusion perpetua, ordering him to pay P15,000 in indemnity.
ISSUE
Whether the guilt of accused-appellant Alejandro Devilleres for the crime of rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction, modifying the indemnity to P50,000. The Court found Lorena’s testimony to be credible, straightforward, and consistent. She provided a detailed and unshaken account of how her father used a gaff to intimidate her and forcibly consummated the sexual act. The medical findings, while noting the lacerations were healed by the time of examination, corroborated her claim of prior sexual intercourse. The defense of denial and alibi was weak and self-serving, especially when juxtaposed with the positive identification by the victim.
The legal logic is clear: in rape cases, the credibility of the complainant is paramount. The Court emphasized that when the victim’s testimony is credible, as here, it is sufficient to sustain a conviction. Furthermore, the relationship between the accused and the victim—father and daughter—establishes moral ascendancy and influence, which substitutes for the degree of force required in other circumstances. In this incestuous context, the use of a weapon like a gaff only magnified the intimidation and force employed. The trial court’s assessment of witness credibility is accorded great respect, and no compelling reason was presented to overturn its findings.