G.R. No. 121906 September 17, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE DE LOS SANTOS y CACHUELO, accused-appellant.

FACTS

The case involves the rape of the minor Nanette (or Nhanette) de los Santos by her natural father, accused-appellant Felipe de los Santos. The complaint alleged that on September 12, 1994, in Quezon City, the accused used force and intimidation to have carnal knowledge with the 13-year-old complainant against her will. The prosecution presented Nanette, who testified that her father brought her to an isolated apartment after they ate at a carinderia following his jeepney route. At the apartment, he ordered her to undress and, despite her initial refusals, she complied out of fear of his anger. He then raped her and told her not to tell anyone. The next day, Nanette fled and eventually sought help from a barangay tanod, Nelson Bartolay, leading to a medical examination by Dr. Owen Lebaquin, who found healed hymenal lacerations. The defense, comprising the accused, his wife Cathy, and daughter Rivera, denied the charge. Accused-appellant claimed he was a stay-in driver/mechanic, could not have been present on the date of the alleged rape, and that the complaint was fabricated by Nanette in retaliation for his maltreatment after she stopped schooling and joined a “barkada.” The trial court found Nanette’s testimony credible, noting its consistency and bolstered by an ocular inspection of the crime scene. It rejected the defense’s version due to contradictions and improbabilities, convicting accused-appellant of rape and imposing the death penalty.

ISSUE

Whether the trial court erred in giving credence to the testimony of private complainant Nanette de los Santos and in convicting accused-appellant of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. It held that the trial court correctly gave weight to Nanette’s testimony, which was found to be credible, categorical, logical, and straightforward. The Court rejected accused-appellant’s arguments that Nanette’s conduct was against human experience and that she had opportunities to escape, noting the moral ascendancy and influence he exerted as her father. The Court also found no merit in the claim that the charge was motivated by retaliation, as the delay in filing did not undermine her credibility, and the gravity of a rape charge made it an unlikely fabrication for mere retaliation. The medical findings corroborated her testimony. The death penalty was affirmed as the crime was committed by a parent against a minor child. The Court modified the civil liability, ordering accused-appellant to indemnify the victim with Seventy-Five Thousand Pesos (P75,000.00) as compensatory damages, in addition to the Fifty Thousand Pesos (P50,000.00) moral damages awarded by the trial court.