G.R. No. 122909 June 10, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICTOR REÑOLA y CORPEN, accused-appellant.

FACTS

The accused-appellant, Victor Reñola, was convicted by the Regional Trial Court of Makati and sentenced to death four times for the rape of his 16-year-old daughter, Marivic Reñola, on four separate occasions in October 1994 and February 1995. The prosecution evidence established that the accused, armed with a balisong, sexually assaulted the victim inside their home while her mother was out. The victim resisted but was overpowered and threatened with death if she reported the incidents. The assaults followed a similar pattern of force and intimidation. The victim eventually confided in a neighbor, leading to a confrontation with her mother and the subsequent filing of criminal complaints. A medico-legal examination confirmed the victim was in a non-virgin state with healed hymenal lacerations consistent with the 1994 incidents.
The defense hinged on denial, arguing the lack of fresh physical injuries and recent medical evidence of sexual activity to corroborate the last alleged rape in February 1995. The accused-appellant challenged the credibility of the victim’s testimony, suggesting the charges were fabricated. The trial court found the victim’s account credible and convicted the accused, imposing the supreme penalty for each count of rape, prompting this automatic review.

ISSUE

The core issue is whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt, and if so, whether the imposition of the death penalty was proper for all four counts.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The Court upheld the trial court’s assessment of the victim’s credibility, which was categorical, consistent, and unwavering even under cross-examination. The Court ruled that the testimony of a rape victim, if credible, is sufficient to sustain a conviction. The medico-legal findings, while not showing recent trauma for the February 1995 incident, were consistent with the victim’s account of prior assaults and the expert explanation that injuries could have healed within the four-day interval before examination. The defense of denial cannot prevail over the positive and credible identification by the victim.
Regarding the penalty, the Court applied Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659. The death penalty is mandated when the rape is committed with a deadly weapon or by a parent against a child under eighteen. However, for the three counts in October 1994 (Criminal Cases Nos. 95-1114 to 95-1116), the informations failed to allege the qualifying circumstance of relationship, a necessary factual averment for imposing the higher penalty. Consequently, for these three cases, the penalty is reduced to reclusion perpetua. For the February 1995 rape (Criminal Case No. 95-708), where the information expressly alleged the father-daughter relationship, the imposition of the death penalty was affirmed. The Court also modified the awards of civil indemnity.