GR 116716; (September, 1996) (Digest)
G.R. Nos. 116716-18 September 30, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO GABAN Y FROMENTO, accused-appellant.
FACTS
The accused-appellant, Antonio Gaban, was convicted by the trial court for three counts of rape committed against his 15-year-old daughter, Cristina. The incidents occurred in their home in Masbate on separate Saturdays in April, September, and November of 1990. Antonio would threaten Cristina with a knife when his wife was away marketing, forcing her into submission. Fearing his threats to kill her and her family, Cristina initially kept silent. She eventually confided in a relative in February 1991, leading her mother to discover the crimes. Overwhelmed by shame, the mother committed suicide in September 1991. After her burial, Antonio sent Cristina a letter pleading for forgiveness, but she proceeded to file a complaint.
ISSUE
The core issue is whether the prosecution evidence, primarily Cristina’s testimony, sufficiently proves Antonio Gaban’s guilt beyond reasonable doubt for three counts of rape, overcoming his defenses of alibi and alleged fabrication.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the credibility of the victim’s testimony and the weakness of the defense. The Court upheld the trial court’s assessment, giving it great weight as no material facts were overlooked. Cristina’s detailed, candid, and straightforward narration of the traumatic events was found inherently credible. It is improbable for a young, modest country girl to fabricate such a grave accusation against her own father, exposing herself to public shame, unless motivated by truth and a desire for justice. Her testimony alone, especially against a close relative, is sufficient to sustain conviction.
The defenses were rejected. Alibi is inherently weak and requires proof of physical impossibility to be at the crime scene, which appellant failed to establish. His claim of being in Navotas during the rapes was uncorroborated and belied by evidence of his family’s continued residence in Masbate. The defense of fabrication due to his being a womanizer was deemed incredible and unsupported. Most damningly, his letter begging for forgiveness constitutes a tacit admission of guilt. The penalties of reclusion perpetua for each count were affirmed, with modifications to the awards for moral and exemplary damages.