GR 119165; (September, 1997) (Digest)
G.R. No. 119165 September 26, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SERGIO BETONIO, accused-appellant.
FACTS
Sergio Betonio was charged with the rape of his niece, thirteen-year-old Loreta Betonio, in Guindulman, Bohol, around April 1990. The Information alleged he used force, intimidation, and a knife. The prosecution presented Loreta, who testified that her uncle, with whom she was living, raped her on multiple occasions, threatening her with a knife. Her mother, Bertila, corroborated the report. Dr. Jean Tabuga de Paz, who examined Loreta in May 1991, testified that her physical findings, including healed lacerations, were consistent with repeated sexual intercourse. The defense presented a different narrative, claiming a consensual “forbidden love affair” and alleging the complaint was fabricated due to family resentment over Loreta’s pregnancy by another man. The Regional Trial Court convicted Betonio of rape and sentenced him to reclusion perpetua.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized the well-established doctrine that the trial court’s assessment of witness credibility is accorded the highest respect, as it is in the best position to observe demeanor and sincerity. The Court found no reason to deviate from the trial judge’s conclusion that Loreta’s testimony was credible, straightforward, and consistent. Her detailed account of the threats and assaults, coupled with her tender age and the moral ascendancy wielded by her uncle-in-loco-parentis, rendered her testimony highly convincing.
The defense of a love affair was rejected as inherently incredible and a mere fabrication to escape liability. The Court noted that such a claim was contrary to human nature and experience, especially given the victim’s age and the accused’s familial authority. The medical findings, while negative for sperm, corroborated the claim of repeated intercourse due to the presence of healed lacerations. The Court modified the damages, deleting the unsupported award of moral damages but granting P50,000.00 as civil indemnity ex delicto, which is mandatory upon conviction for rape. The award of P3,000.00 for actual expenses was affirmed.