G.R. No. 130631 ; August 30, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEGUNDO CANO, accused-appellant.

FACTS

The accused-appellant, Segundo Cano, was convicted by the Regional Trial Court for two counts of rape committed against his then 15-year-old daughter, Juanita Cano, on September 14 and 16, 1985. The incidents occurred in Balatan, Camarines Sur. In the first instance, inside their home, Segundo poked a bolo at Juanita, forcibly removed her clothes, and had carnal knowledge with her while standing, threatening to kill her if she reported it. Two days later, while Juanita was gathering vegetables on their farm, Segundo again approached her with a bolo, dragged her to a stony area, and raped her. Juanita immediately fled and worked as a housemaid in another city, severing contact with her family. She filed formal complaints only in April 1996 after learning her father faced other charges.
The defense presented denial and alibi, claiming Juanita had left home in April 1985 to work and only returned to file false charges instigated by relatives with personal grudges against him. The defense also presented witnesses, including the accused’s wife and other children, to support the claim that Juanita was not present in the household during the alleged rape dates in September 1985.

ISSUE

The core issue is whether the guilt of the accused-appellant for two counts of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses, particularly Juanita. Her detailed and consistent narration of the traumatic events, including the use of a bolo and specific threats, was found credible and natural for a victim of such a crime, especially given her young age and the moral ascendancy and intimidation exerted by her own father. The delay of over a decade in reporting the crime was sufficiently explained by her continued fear of the accused, her immediate flight from home, and the lack of familial support when she initially told her mother, who did not believe her.
The testimony of Claudio Sinfuego, an eyewitness to the second rape, provided crucial corroboration. His account contained specific details only an observer could provide, and his inaction during the crime out of fear for both Juanita’s and his own safety did not diminish his credibility. The defense’s theory of fabrication motivated by family disputes was rejected for being unsubstantiated and insufficient to overthrow the positive identification and credible testimonies of the prosecution. The Court modified the damages awarded, adding civil indemnity of P50,000 for each count of rape in line with prevailing jurisprudence.