GR 130713; (January, 2000) (Digest)
G.R. No. 130713 January 20, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GABRIEL FLORES, accused-appellant.
FACTS
The Regional Trial Court convicted Gabriel Flores of the rape of his 14-year-old stepdaughter, Jennifer Flores, and imposed the death penalty. The prosecution evidence established that in the early morning of April 13, 1996, Flores entered Jennifer’s room, touched her breast, ordered her to undress, and had carnal knowledge with her after threatening to kill her. Jennifer reported the incident to a neighbor and later to her mother, leading to Flores’s arrest. A medico-legal report confirmed sexual abuse, and Flores allegedly gave a written admission to Jennifer’s mother. The defense denied the accusation, claiming Jennifer fabricated the charge due to resentment over being scolded for having a boyfriend.
ISSUE
Whether the trial court erred in convicting accused-appellant of qualified rape punishable by death.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of Jennifer’s testimony as credible, natural, and convincing, which is sufficient to sustain a rape conviction. However, the Court ruled that the crime committed was simple rape, not qualified rape punishable by death. For the death penalty to apply, the information must specifically allege both the minority of the victim and her relationship to the offender as qualifying circumstances. The information in this case failed to allege Jennifer’s age. Furthermore, the relationship as stepfather was not properly proven, as the evidence only showed that Flores was the common-law spouse of Jennifer’s mother, not a legal stepfather. Consequently, the qualifying circumstances were not duly alleged and proven. Appellant is guilty only of simple rape, punishable by reclusion perpetua. The Court modified the damages, awarding P50,000 as civil indemnity, P50,000 as moral damages, and P20,000 as exemplary damages, the latter granted due to the presence of the aggravating circumstance of relationship.