G.R. No. 117684 January 30, 1997
People of the Philippines vs. Clodualdo Cabillan

FACTS

The accused-appellant, Clodualdo Cabillan, was convicted by the trial court of raping his stepdaughter, Alienaven Aida Devaras. The information alleged that on August 7, 1992, in Sto. Tomas, Davao, Cabillan had carnal knowledge of the 15-year-old Alienaven by means of force and intimidation. Alienaven testified that on that day, while her mother was away, Cabillan sent her younger siblings out of the house, threatened her with a knife, and forcibly raped her. She reported the incident, leading to a medical examination which revealed old, healed lacerations on her hymen.
Alienaven further testified that the rape on August 7, 1992, was not an isolated incident but the culmination of years of sexual abuse that began when she was eleven. She stated the abuse occurred two to three times a week. The accused denied the charges, arguing that the rape could not have occurred without attracting the neighbors’ attention and that, at 62 years old, he was incapable of the sexual act. He also insinuated that Alienaven had prior sexual experience.

ISSUE

The core issue is whether the trial court erred in convicting Clodualdo Cabillan of rape based on the testimony of the private complainant.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Alienaven’s credibility, finding her testimony to be straightforward, candid, and consistent with the typical narration of a young rape victim. The Court emphasized that it is highly improbable for a young girl to fabricate a story so humiliating to herself and her family, especially against her own stepfather, unless it were true. Her willingness to undergo medical examination and public trial lends further credence to her account.
The Court rejected Cabillan’s defenses as unconvincing. The claim that the act would have attracted neighbors holds no merit, as lust respects no time or place, and rape can be committed even in occupied areas. His assertion of physical incapacity due to age was unsupported by evidence; he himself admitted to having no ailment and performing heavy work. Finally, any imputation of the victim’s prior sexual conduct is irrelevant to the specific act of rape committed against her will on August 7, 1992. The medical findings corroborated her testimony of prior sexual abuse. Thus, the guilt of the accused was proven beyond reasonable doubt.