G.R. No. 124097 June 17, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS BONGHANOY, accused-appellant.

FACTS

Accused-appellant Carlos Bonghanoy was charged with the rape of his 14-year-old niece, Baby Jane de Guzman. The prosecution evidence established that on June 28, 1994, Bonghanoy, under the pretext of searching for his wife, persuaded the victim’s parents to allow Baby Jane to accompany him. He then led her to an elementary school compound, threatened her with a rock, and forcibly had carnal knowledge of her. The victim reported the rape to her mother the following morning, leading to a medical examination which confirmed a recent hymenal laceration compatible with loss of virginity.
In his defense, Bonghanoy denied the accusation, presenting an alibi that he was engaged in a drinking session during the time of the alleged crime. He claimed the charge was motivated by his sister’s jealousy. The trial court found him guilty of rape qualified by minority and relationship, imposing the death penalty under Republic Act No. 7659, which mandated automatic review by the Supreme Court.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant of qualified rape and imposing the death penalty, despite his defense of alibi and his challenge to the sufficiency of the prosecution’s evidence and the clarity of the trial court’s decision.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of the victim’s testimony as credible, spontaneous, and consistent, which was corroborated by medical findings. The defense of alibi was properly rejected as inherently weak and unsubstantiated by clear and convincing evidence, especially in light of the positive identification by the victim. The Court also found that the trial court’s decision, while lacking in literary style, substantially complied with the constitutional requirement to state the facts and the law clearly.
However, the Court modified the legal qualification of the crime. The information alleged force and intimidation but failed to specifically allege the qualifying circumstances of minority and relationship. While these circumstances were proven during trial, the Court ruled that an accused cannot be convicted of a qualified offense unless the qualifying circumstances are expressly and precisely stated in the indictment. Therefore, the crime committed was simple rape, not qualified rape punishable by death. The penalty was reduced to reclusion perpetua. The civil indemnity was set at P50,000, with moral damages of P50,000 and exemplary damages of P10,000, the latter awarded due to the proven relationship as a generic aggravating circumstance.