G.R. No. 127574 . July 20, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO SUGANO y ALARCON, accused-appellant.

FACTS

The accused-appellant, Wilfredo Sugano, was charged with three counts of rape committed against his fifteen-year-old daughter, Lani M. Sugano, in June, July, and August of 1994 in Cagayan de Oro City. The complaints alleged that the acts were committed by force and with lewd design, aggravated by the accused being the victim’s father. At trial, Lani testified that each rape occurred in the early morning inside their market stall while her mother was away. She described being awakened by her father on top of her, her attempts to resist, and being physically overpowered—slapped on one occasion and beaten with a stick on another. She reported each incident to her mother, who refused to believe her, leading Lani to eventually flee and seek help from an aunt.
The defense presented a denial and alibi, claiming the charges were fabricated due to familial discord. The trial court found the accused guilty on all three counts, imposing the death penalty for each crime, citing the qualifying circumstances of minority and relationship. The case was automatically elevated to the Supreme Court for review.

ISSUE

The core issue is whether the guilt of the accused-appellant for three counts of qualified rape was proven beyond reasonable doubt, warranting the imposition of the death penalty.

RULING

The Supreme Court affirmed the convictions. The Court held that Lani’s testimony was credible, categorical, and consistent. The defense of denial and alibi cannot prevail over the positive identification by the victim, especially given the details of her ordeal and her immediate attempts to seek help. The medical certificate, while not showing fresh lacerations due to the lapse of time, corroborated her claim of lost virginity. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction.
The crimes were properly qualified under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659 . The twin circumstances of the victim being under eighteen years old and the offender being the victim’s father were both alleged in the informations and proven during trial. These circumstances mandate the penalty of death. The Court modified the damages, awarding P75,000.00 as civil indemnity and P50,000.00 as moral damages for each count. The records were ordered transmitted to the Office of the President pursuant to the rules on the execution of the death penalty.