GR 128363; (May, 2004) (Digest)
G.R. No. 128363 ; May 27, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. EMILIANO CAPAREDA, appellant.
FACTS
The appellant, Emiliano Capareda, was convicted by the Regional Trial Court of four counts of rape against his 13-year-old grandniece, Rizalyn Lufera. The incidents occurred in June and July 1992 within the victim’s family home, where the appellant was temporarily staying. The prosecution established that the appellant, through force, intimidation, and the use of a bolo, sexually assaulted the victim on multiple occasions while she was studying in her room. The victim, fearing for her life and the lives of her family due to the appellant’s threats, initially did not report the rapes. The defense interposed denial and alibi, claiming he was elsewhere during the alleged incidents.
ISSUE
The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the victim’s testimony to be credible, straightforward, and consistent, detailing the specific acts of sexual assault and the threats that compelled her submission. The defense of alibi was properly rejected as it was not physically impossible for the appellant to have been at the crime scene. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount, especially when the victim is a minor. The victim’s initial silence, explained by the appellant’s threats of death, was reasonable and did not undermine her credibility.
Regarding the penalty, the Court modified the trial court’s decision. While the crimes were committed under the Revised Penal Code, the Court correctly imposed reclusion perpetua for each count, as the death penalty under Article 335 could not be applied due to the failure to allege the victim’s minority and her relationship to the offender as qualifying circumstances in the Informations. The relationship was properly treated only as an aggravating circumstance. The Court awarded civil indemnity, moral damages, and exemplary damages to the victim, consistent with prevailing jurisprudence. The appellant’s guilt was thus established beyond reasonable doubt.