G.R. No. 128888 December 3, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CHARITO ISUG MAGBANUA, accused-appellant.

FACTS

Accused-appellant Charito Isug Magbanua was charged with the rape of his daughter, Poblica Magbanua. The Information alleged the crime occurred sometime in 1991 in Occidental Mindoro. During trial, Poblica testified that in 1991, at age 13, her father raped her at knifepoint. This abuse allegedly continued multiple times monthly until 1995, resulting in her pregnancy and the birth of a son in November 1995. She initially concealed the identity of the father due to threats but later disclosed it to her uncle, Leonilo Magbanua, who assisted her in filing a complaint. Dr. Arlene Sy’s medical examination confirmed Poblica’s non-intact hymen and other physical conditions consistent with sexual activity and childbirth.
The defense presented a different account. Appellant denied the allegations, claiming he was at work during the alleged initial incident. He asserted that the complaint was fabricated by his brother, Leonilo, due to a longstanding family land dispute. He suggested that Poblica’s pregnancy was caused by a neighbor named Ricky Pacaul, whom she had initially named.

ISSUE

The core issue was whether the prosecution proved beyond reasonable doubt that appellant committed rape, considering the credibility of the victim’s testimony against the defense of denial and alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found Poblica’s testimony to be credible, straightforward, and consistent. The detailed account of the initial rape and the subsequent repeated abuses, coupled with the resulting pregnancy, constituted strong evidence. 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 identification and categorical testimony of the complainant. The alleged motive of a land dispute was deemed insufficient to compel a daughter to falsely accuse her father of a grave crime and bear the social stigma involved.
However, the Court reduced the penalty from death to reclusion perpetua. The crime was committed in 1991, but the case was filed in 1996 under the provisions of Republic Act No. 7659, which imposed the death penalty for rape when the victim is under 18 and the offender is a parent. The Court ruled that applying the death penalty for acts committed before the law’s effectivity would constitute a prohibited ex post facto law, as it would impose a heavier penalty than what was prescribed at the time of the commission of the offense. Thus, the penalty proper at the time of the crime’s commission was reclusion perpetua.