G.R. No. 127356 June 29, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DAVID SILVANO y HAYAG, accused-appellant.

FACTS

The accused-appellant, David Silvano, was charged with the rape of his daughter, Sheryl Silvano, who was sixteen years old at the time of the incident on January 23, 1996. The prosecution evidence established that Sheryl was sleeping in her room in their Quezon City home when her father, appearing intoxicated, awakened her to scold her for coming home late. Under the pretense of administering punishment—a practice she claimed had occurred since she was thirteen—he proceeded to undress her, kiss her breasts, perform cunnilingus, and ultimately have sexual intercourse with her despite her pleas and physical resistance. Sheryl later confided in her mother and grandmother, leading to the filing of charges.
At trial, the defense presented a denial and alibi, claiming Sheryl fabricated the story due to resentment over strict parental discipline. The defense also questioned the credibility of the victim’s testimony, pointing to alleged inconsistencies. The Regional Trial Court convicted David Silvano of rape and, due to the qualifying circumstance of the victim being under eighteen and the offender being her parent, sentenced him to death and ordered him to pay indemnity and damages.

ISSUE

The core issue for the Supreme Court’s review was whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalties and awards. The Court found the testimony of the victim, Sheryl, to be credible, consistent, and worthy of belief. It ruled that her detailed account of the sexual assault, delivered in a straightforward manner, constituted proof beyond reasonable doubt. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi could not prevail over the positive and categorical identification by the victim. The alleged inconsistencies in her testimony were minor and did not affect the core facts of the violation.
The crime was qualified under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659 , because the victim was under eighteen years of age and the offender was her parent. However, following prevailing jurisprudence, the Court reduced the penalty from death to reclusion perpetua, as the information did not specifically allege the victim’s minority and her relationship to the accused as qualifying circumstances for the imposition of the death penalty in a manner that complied with strict constitutional requirements. The Court affirmed the award of P50,000.00 as civil indemnity and P50,000.00 as moral damages, which are automatically granted in rape convictions.