G.R. Nos. 122114-17; January 20, 2004
PEOPLE OF THE PHILIPPINES, Appellee, vs. EDUARDO LIMOS y DE VERA, Appellant.

FACTS

The appellant, Eduardo Limos, was convicted by the Regional Trial Court of four counts of rape against his niece, Janice C. Ligot. The incidents occurred on August 9, 1993, August 13, 1993, August 15, 1994, and August 17, 1994, in Pozorrubio, Pangasinan. In each instance, the prosecution established that Limos, armed with a kitchen knife, used force, intimidation, and threats to kill to subdue the victim and have carnal knowledge of her against her will. Janice, who was 12 to 14 years old during the assaults, testified in detail about the rapes, her resistance, and her fear that prevented her from immediately reporting the crimes.
The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents. The trial court rejected this defense, giving full credence to the clear, consistent, and categorical testimony of the victim. The court found the appellant guilty and initially imposed the death penalty for two counts, but the case was elevated to the Supreme Court for automatic review following the imposition of capital punishment.

ISSUE

The core issue for the Supreme Court’s review was whether the guilt of the appellant for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the appellant’s conviction but modified the penalties. The Court meticulously examined the records and found the victim’s testimony to be credible, natural, convincing, and consistent with human nature and the normal course of things. Her detailed account of the successive rapes, including the use of a deadly weapon and specific threats, remained unshaken during cross-examination. The Court reiterated the doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The defense of denial and alibi, inherently weak and unsupported by clear and convincing evidence, could not prevail over the positive identification by the victim.
Regarding the penalty, the Court applied the prevailing rules on the imposition of the death penalty. It noted that while the use of a deadly weapon qualified the rape under Article 335 of the Revised Penal Code, the death penalty could not be imposed because the qualifying circumstance of the use of a deadly weapon was not alleged in the Informations for Criminal Cases Nos. U-8342 and U-8343. Consequently, the Court modified the sentences, imposing the penalty of reclusion perpetua for all four counts. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages to the victim.