GR 122473; (June, 2000) (Digest)
G.R. No. 122473 ; June 8, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARTECHE ANTONIO y PAYAGAN, accused-appellant.
FACTS
The accused, Arteche Antonio, was charged with the rape of his 13-year-old daughter, Arnie S. Antonio. The incident allegedly occurred on January 15, 1992, in their one-room dwelling in Cateel, Davao Oriental. Arnie testified that she was awakened by her father, who covered her mouth, threatened her with a bolo, and forcibly had carnal knowledge of her while her mother and siblings slept nearby. She did not immediately report the assault due to fear of her father’s violent temper. She later confided in her mother, who expressed helplessness. Arnie eventually escaped to Davao City and, when her father attempted to retrieve her, disclosed the rape to her employer, leading to the filing of a complaint. A medical examination revealed a healed hymenal laceration.
The defense presented a denial and alibi. Arteche claimed he slept twelve feet away from Arnie and that she fabricated the charge due to a prior incident where he hit her for losing money. His daughter Roselyn corroborated his account of the sleeping arrangements, testifying that nothing unusual occurred that night.
ISSUE
Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Arnie, to be credible, straightforward, and consistent. The medical findings, though indicating a healed laceration, were consistent with her account of the rape occurring months prior. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and Arnie’s detailed narration of the assault, including the use of a bolo and the force employed, was convincing. Her delay in reporting was sufficiently explained by her well-founded fear of her father, who had a history of violence, including a prior case filed by her mother.
The defense of denial and alibi was inherently weak and could not prevail over Arnie’s positive identification. The alleged motive for fabrication—being hit with a notebook—was trivial and insufficient to explain a charge as grave as parricidal rape. The Court upheld the penalty of reclusion perpetua, as the death penalty was constitutionally proscribed at the time of the crime’s commission. The award of moral damages was affirmed, and, following prevailing jurisprudence, the Court modified the decision to additionally award civil indemnity ex delicto in the amount of P50,000.00.