GR 124895; (March, 2000) (Digest)
G.R. No. 124895 ; March 1, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN DE LOS REYES y DIOLA, accused-appellant.
FACTS
Accused-appellant Ruben de los Reyes was charged with seven counts of rape against his two daughters. In Criminal Cases Nos. R95-017 and R95-018, he was accused of raping his sixteen-year-old daughter, Bernadette, on August 28, 1994, and January 26, 1992, respectively. In Criminal Cases Nos. R95-022 to R95-026, he was accused of raping his fourteen-year-old daughter, Melanie, on five separate occasions in September and November 1994. The Regional Trial Court found him guilty beyond reasonable doubt on all counts, imposing the death penalty for six counts and reclusion perpetua for one count, along with moral damages.
ISSUE
The core issue for automatic review was whether the trial court correctly convicted the accused-appellant of seven counts of rape based on the evidence presented.
RULING
The Supreme Court affirmed the convictions. The Court upheld the trial court’s assessment of the credibility of the complainants, Bernadette and Melanie. Their testimonies were found to be candid, consistent, and convincing in detailing the sexual assaults committed by their own father. The Court emphasized that in rape cases, the credibility of the victim is paramount, and the testimonies of young victims, when straightforward and unshaken, are accorded full weight. The defense of denial and alibi proffered by the accused-appellant was deemed weak and unsubstantiated, especially against the positive identification by the victims.
Regarding the penalties, the Court affirmed the imposition of the death penalty for the six counts where the qualifying circumstance of the victim being under eighteen years of age and the offender being the parent of the victim was duly alleged and proven, pursuant to Republic Act No. 7659 . The penalty of reclusion perpetua for one count (R95-018) was also affirmed, as the information for that charge did not allege the victim’s minority, a necessary element for the death penalty at the time. The Court modified the awards by ordering the accused-appellant to pay civil indemnity ex delicto in addition to moral damages, setting it at P75,000 for each death penalty case and P50,000 for the case with reclusion perpetua, in line with prevailing jurisprudence. The records were ordered forwarded to the Office of the President pursuant to law.