G.R. Nos. 130493-98; April 28, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ROGELIO LAYUGAN Y FURUC, appellant.

FACTS

The appellant, Rogelio Layugan, was charged with five counts of rape committed against his 14-year-old daughter, Evelyn Layugan, on various dates in 1995 and 1996 in Angadanan, Isabela. The prosecution evidence established that the appellant sexually assaulted Evelyn on multiple occasions, often when her mother was away. He used threats and intimidation, reminding her that he had killed her eldest brother, to ensure her submission. Evelyn eventually reported the rapes to her mother, leading to a medical examination which revealed fresh and old lacerations consistent with sexual intercourse.
The appellant denied the accusations, interposing alibi and claiming he worked as a farm caretaker and slept away from home during the alleged incidents. He admitted to killing his son but asserted he loved his children and could not have committed the acts. The Regional Trial Court convicted him of five counts of rape and imposed the death penalty for each count, along with moral damages.

ISSUE

The core issue for automatic review is whether the prosecution proved the appellant’s guilt for five counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court found the testimony of the victim, Evelyn, to be credible, categorical, and consistent. Her detailed account of the sexual assaults, coupled with the medico-legal findings of vaginal lacerations, constituted proof beyond reasonable doubt. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The appellant’s defenses of alibi and denial were inherently weak and could not prevail over the positive identification and straightforward narration of the victim. The Court also noted that the relationship of father and daughter, and the appellant’s history of violence, bolstered the credibility of the victim’s claim of intimidation.
However, the Court modified the penalty. While the crimes were committed under the death penalty law ( Republic Act No. 7659 ), the requisite qualifying circumstance of the victim’s minority (below 18) and her relationship to the offender (father) must be both alleged in the information and proved during trial. The Court found that while the victim’s age (14) was proven, the Informations failed to specifically allege her exact age. Following prevailing jurisprudence, this fatal omission warrants the reduction of the penalty from death to reclusion perpetua for each count. The award of moral damages was increased to conform with established guidelines.