GR 117406; (January, 2001) (Digest)
G.R. No. 117406 . January 16, 2001.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO GARCIA y BOTON, accused-appellant.
FACTS
The accused-appellant, Alberto Garcia, was charged with the rape of his 13-year-old daughter, Grace Garcia, on or about December 11, 1992, in Marikina. The prosecution evidence established that the accused-appellant, arriving home drunk, found the victim alone. He pinned her down, fondled her, and struck her jaw, rendering her unconscious. Upon regaining consciousness, she found herself undressed, and the accused-appellant proceeded to have carnal knowledge of her. He then threatened to kill her and her family if she reported the incident. Grace immediately reported the rape to her mother, and they subsequently filed a police report and obtained a medico-legal examination.
The defense failed to present any evidence. Despite being granted opportunities, accused-appellant did not file a demurrer to evidence. The trial court subsequently declared that he had waived his right to present evidence and considered the case submitted for decision based solely on the prosecution’s evidence.
ISSUE
Whether the trial court erred in convicting accused-appellant of rape based solely on the testimony of the complainant.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the accused may be convicted solely on the credible testimony of the victim. The trial court’s assessment of witness credibility is accorded great respect, and no compelling reason was shown to overturn its findings. The testimony of Grace Garcia was found to be clear, spontaneous, and rich in detail, consistent with human nature and the normal course of events. Her immediate reporting of the crime to her mother and the authorities bolstered her credibility.
The Court further ruled that the failure of the defense to present evidence or to effectively cross-examine the prosecution witnesses left the prosecution’s evidence uncontroverted. Moreover, the Court held that even assuming arguendo that the use of force was not sufficiently proven, the conviction was still justified. The moral ascendancy of a father over his daughter substitutes for intimidation or force as an element of rape. The Court, however, modified the civil liabilities, increasing the indemnity to P50,000.00 and awarding an additional P50,000.00 as moral damages in accordance with prevailing jurisprudence.