G.R. No. 130586; January 29, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. FRANCISCO BLANCAFLOR, appellant.

FACTS

The appellant, Francisco Blancaflor, was convicted of rape and sentenced to death by the Regional Trial Court. The victim, Mylene Rueda, his fourteen-year-old stepdaughter, testified that in July 1995, he raped her in their home early one morning. She stated she was awakened by the appellant on top of her, with his penis at her vagina, while he pinned her hands and threatened her with a gun. She did not immediately report the incident due to fear, confiding only in her mother three weeks later, which led to a quarrel but no formal action. The crime was formally reported over a year later after Mylene’s deteriorating school performance prompted her class adviser to intervene, leading to assistance from a guidance counselor and a non-governmental organization.
The defense claimed the accusation was fabricated out of resentment because the appellant disciplined Mylene for her late-night habits. Defense witnesses testified to his good moral character. The trial court found Mylene’s testimony credible, convicting the appellant and imposing the death penalty, citing the qualifying circumstance of the victim being under eighteen and the offender being a stepfather, pursuant to Republic Act No. 7659.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, particularly concerning the credibility of the victim’s testimony and the propriety of the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court upheld the trial court’s assessment of Mylene’s credibility, emphasizing that testimonies of child-victims of rape are given full weight and credit. The delay in reporting was deemed not unnatural, as it is common for victims, especially minors abused by a parental authority figure within the home, to be overcome by fear and shame. The Court found her detailed account of the rape, including the threat with a gun, to be consistent and convincing, rendering the appellant’s denial inherently weak.
Regarding the penalty, the Court ruled that the death penalty could not be imposed. While the Information alleged the victim was a stepdaughter, it failed to specifically allege the victim’s age as under eighteen, which is an essential element for the imposition of the death penalty under the law at the time. This omission constituted a failure to properly allege a qualifying circumstance, warranting the reduction of the penalty to reclusion perpetua. The Court affirmed the award of civil indemnity and additionally awarded moral and exemplary damages due to the abuse of confidence and the commission of the crime in the victim’s dwelling.