GR 120281; (July, 1998) (Digest)
G.R. No. 120281 July 8, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSCAR ESCALA, accused-appellant.
FACTS
Wilma Escala, the 14-year-old complainant, accused her father, Oscar Escala, of rape. The family lived in a small shanty in Tacloban City, all sleeping together in a single room sharing one mat, mosquito net, and blanket. Wilma testified that her father first raped her when she was 12 years old and a Grade VI pupil. The rapes occurred repeatedly, three to four times a week, usually at night before her father went to bed, and sometimes during the day when her mother was absent. Her father threatened her with a knife or nightstick each time. Wilma kept silent until she confided in her common-law husband, Enrique Batis, after he discovered she was no longer a virgin. She decided to file charges after learning her 13-year-old sister, Alma, was also being raped by their father. Oscar Escala was charged with rape under an amended information. He pleaded not guilty, interposing denial and claiming the charge was orchestrated by Enrique Batis as leverage because he (Oscar) had threatened to charge Enrique with kidnapping with rape. The Regional Trial Court convicted Oscar Escala and sentenced him to death, prompting an automatic review by the Supreme Court.
ISSUE
The main issue is the credibility of Wilma Escala’s testimony and whether the prosecution proved the guilt of the accused beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found Wilma’s testimony credible, straightforward, and consistent. It detailed her account of the rapes, including the specific instance in July 1994, where she described being raped at night while the family slept nearby, with her father threatening her with a knife. The Court rejected the appellant’s defense of denial and alibi, noting that such defenses cannot prevail over the positive and categorical testimony of the victim. The Court also addressed the penalty, noting that the death penalty was properly imposed under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, because the rape was committed by a parent against a minor child. The Court’s decision included a note that four members, while maintaining their view that the death penalty law is unconstitutional, bowed to the majority ruling on its constitutionality and imposition.