G.R. No. 130092 . July 26, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO BRANDARES y BOTON, accused-appellant.

FACTS

The case involves the automatic review of the death penalty imposed by the Regional Trial Court of Misamis Oriental on accused-appellant Alfredo Brandares for the rape of his thirteen-year-old daughter, Arcelyn C. Brandares. The prosecution established that in August 1994, while the victim was sleeping in a room she shared with her father and younger sister, the accused-appellant laid beside her, placed his hand over her mouth, removed her underwear, and forcibly had carnal knowledge with her, threatening to kill her if she revealed the incident. The victim reported the rape to her mother, Celsa, in December 1994 after her mother noticed her depression and physical condition. A medical examination by Dr. Amado Piit confirmed healed hymenal lacerations consistent with sexual intercourse.
The defense, seeking acquittal, denied the charges. Accused-appellant claimed the complaint was fabricated by his wife, Celsa, because he forbade her from working as a domestic helper. A defense witness, Edna Brandares, testified that Celsa had inserted her fingers into the victim’s vagina prior to the medical exam, suggesting this caused the lacerations. Both Arcelyn and Celsa vehemently denied this allegation on rebuttal.

ISSUE

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

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court found the testimony of the victim, Arcelyn, to be credible, straightforward, and consistent. It held that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The Court dismissed the defense’s theory of fabrication as inherently improbable and lacking credible support. It noted that no mother would subject her daughter to the shame and trauma of a rape trial, and concoct a story of incestuous rape, merely due to a marital dispute over employment. The medical findings, while not conclusive by themselves, corroborated the victim’s account of forcible defloration.
The crime was qualified by two circumstances warranting the death penalty under Republic Act No. 7659 : the victim was under eighteen (13) years of age, and the offender was the parent of the victim. Both qualifying circumstances were properly alleged in the information and conclusively proven during trial. The Court modified the damages awarded, increasing the civil indemnity to P75,000.00 in line with jurisprudence for rape punishable by death, and affirmed the P50,000.00 moral damages, but deleted the exemplary damages for lack of legal basis. The decision was affirmed with modifications.