G.R. No. 124559 April 30, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERIBERTO MAGLENTE y CABAHUG, accused-appellant.

FACTS

Accused-appellant Eriberto Maglente was convicted by the Regional Trial Court of eight counts of rape against his daughter, Maylene Maglente, and sentenced to death for each count. The incidents occurred in 1995 in Quezon City after Maylene’s mother left to work abroad. Maylene testified in detail about the eight separate occasions where her father, through force, intimidation, and physical violence, had carnal knowledge of her. She resisted but was threatened, boxed, kicked, and rendered helpless. She did not immediately report the rapes out of fear for herself and her younger sisters, eventually confiding only to her sister and a grandaunt before executing a sworn statement with the police.
The defense presented a denial and alibi, claiming Maylene fabricated the charges due to resentment over his strictness and her desire to live with her grandparents. The medico-legal examination revealed healed lacerations consistent with repeated sexual intercourse, supporting the victim’s testimony. The trial court gave full credence to the complainant’s consistent and categorical narration of events.

ISSUE

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

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court meticulously reviewed the records and found the testimony of the victim, Maylene, to be credible, straightforward, and consistent on material points. The defense of denial and alibi cannot prevail over the positive identification and detailed account of the victim. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and her testimony alone, if credible, is sufficient to sustain a conviction. The medical findings of healed lacerations corroborated her claim of repeated sexual intercourse.
The Court, however, found that the qualifying circumstance of relationship was not properly alleged in the informations. While the complaints stated the accused was the “father of the undersigned,” they failed to specifically allege that the victim is the daughter of the accused, which is required for the imposition of the death penalty under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659 . Consequently, the penalty for each count of rape is reduced to reclusion perpetua. The awards of moral and exemplary damages were affirmed.