G.R. No. 128839 July 20, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GODOFREDO TEVES y LEMEN, accused-appellant.

FACTS

Accused-appellant Godofredo Teves was charged with four counts of rape committed against his thirteen-year-old daughter, Cherry Rose Teves. The informations alleged multiple rapes occurring in 1993 and on specific dates in January 1995 in Kawit, Cavite. At trial, Cherry Rose testified that her father sexually assaulted her on several occasions, often when her mother was out working. She recounted specific instances, including one on January 1, 1995, where her father sent her brother on an errand before molesting her. He consistently threatened to kill her if she reported the abuse. The defense stipulated on the medico-legal report, which indicated the victim was in a non-virgin state physically. Godofredo denied the accusations, claiming they were fabricated because he disapproved of his daughter’s late homecomings and had maltreated her for it.
The Regional Trial Court convicted Godofredo Teves of multiple rape and imposed the death penalty. The case was elevated to the Supreme Court for automatic review, given the capital punishment imposed. The defense argued that the prosecution failed to prove his guilt beyond reasonable doubt, challenging the credibility of the victim’s testimony and the sufficiency of the evidence.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for the crime of multiple rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of the victim’s credibility, finding her testimony to be straightforward, spontaneous, and consistent. The defense of denial and alibi, coupled with an imputed ill motive, was deemed weak and insufficient to overcome the positive identification and detailed narration by the victim. In rape cases, the testimony of the victim, if credible, is sufficient to sustain a conviction. The Court found no reason to deviate from the trial judge’s findings, as he was in the best position to observe the witnesses’ demeanor.
However, the Court reduced the penalty from death to reclusion perpetua. The information for the multiple rape count (Criminal Case No. 3872-95) alleged the crime was committed “sometime in the year 1993.” The Court ruled this allegation was insufficient to constitute a qualifying circumstance for imposing the death penalty under Republic Act No. 7659, which requires that the rape be committed “by two or more persons” or with certain specific aggravating circumstances. The phrase “multiple rape” in the information, without more, did not specifically allege that the accused-appellant conspired with others. A complaint must state the specific qualifying circumstances with particularity to warrant the death penalty. Since the information failed to allege with specificity any qualifying circumstance, the crime was simple rape, punishable by reclusion perpetua. The award of civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence.