G.R. No. 124366 -67 May 19, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE PEREZ y GALVEZ, accused-appellant.

FACTS

The accused-appellant, Jose Perez, a 45-year-old bachelor and barangay hall caretaker, was convicted by the Regional Trial Court of two counts of rape against his 16-year-old niece, Cristina Perez. The informations alleged rapes occurring in the last week of May 1994 and on June 4, 1994, in San Mateo, Rizal. Cristina testified that in the May incident, she was awakened by the appellant, who rendered her unconscious with a cloth placed over her nose and mouth. She awoke with vaginal pain, bleeding, and her clothing disturbed. In the June incident, the appellant again used a cloth to subdue her, threatened her with a balisong knife when she resisted, and raped her. She did not immediately report the assaults due to threats but eventually disclosed them in July 1994 when her pregnancy became apparent. A medico-legal report confirmed her pregnancy, consistent with conception around March 1994, which led to the birth of a child in December 1994.
The defense was a denial, with the appellant claiming the charges were fabricated because the victim’s family was angry he refused to marry her after she became pregnant. The trial court found Cristina’s testimony credible and convicted the appellant of two counts of rape under Article 335 of the Revised Penal Code, sentencing him to reclusion perpetua for each count and awarding civil indemnity.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the complainant is paramount in rape cases. Cristina provided a clear, consistent, and candid narration of the traumatic events, which bore the hallmarks of truth. Her testimony withstood rigorous cross-examination, and her initial silence was reasonably explained by the appellant’s threats and their familial relationship, which instilled fear. The Court rejected the defense of denial and fabrication, noting that no ill motive was proven for the young complainant to falsely accuse her uncle of a grave crime and endure the ordeal of a public trial. The fact that the victim was already pregnant from an alleged earlier assault in March did not negate the commission of the subsequent rapes in May and June. The Court modified the awards, increasing the civil indemnity to P50,000.00 and granting an additional P50,000.00 as moral damages for each count of rape, in line with prevailing jurisprudence.