G.R. No. 128436 December 10, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO DE LEON Y SANTOS, accused-appellant.

FACTS

The prosecution alleged that on July 22, 1992, Amelia de Leon was sleeping in her house when her father, accused-appellant Edgardo de Leon, entered her room smelling of liquor and armed with a knife. He ordered her to undress, struck her with the knife’s handle, and ripped her clothes. He threatened to kill her two-year-old daughter if she did not comply. Fearing for her child’s life, Amelia submitted. Accused-appellant then raped her. Afterward, he warned her not to report the incident. The following morning, Amelia escaped and reported the rape to her godparents and mother, leading to a police report.
The defense presented a denial and alleged a motive for fabrication. Accused-appellant claimed he had refused to consent to Amelia’s marriage earlier that day, leading to a heated argument with Amelia’s mother, Simprosa. Simprosa revealed that Amelia was not his biological daughter. Amelia allegedly threatened to have him imprisoned. He claimed he spent the day drinking and was later arrested based on a false accusation.

ISSUE

Whether the prosecution evidence, primarily the victim’s testimony, is sufficient to prove accused-appellant’s guilt for rape beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court meticulously applied the guiding principles in rape cases, recognizing the difficulty of proof and the need for cautious scrutiny of the complainant’s testimony. It found Amelia’s testimony to be clear, consistent, and credible. She provided a detailed and coherent account of the rape, the threat to her child, and her immediate escape and reporting. The Court ruled that her testimony alone, if credible, is sufficient to sustain a conviction. The alleged inconsistencies were minor and did not affect the core narrative of the crime. The non-presentation of the knife and torn clothing was not fatal, as the testimony was compelling. The Court rejected the defense of denial and alleged motive, finding it weak and insufficient to overcome the positive identification and credible narration of the victim. However, the death penalty was improper. The qualifying circumstance of relationship (stepfather-stepdaughter) under the law at the time required a legitimate filial link. Since Amelia was not accused-appellant’s legitimate daughter, the crime was simple rape, punishable by reclusion perpetua. The award of damages was sustained.