G.R. No. 130985, December 3, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDMUNDO DE LEON y JESUS, accused-appellant.

FACTS

Accused-appellant Edmundo de Leon was charged with seventeen counts of rape committed against his daughter, Marilou de Leon. One count (Criminal Case No. 96-876) pertained to an incident between March and April 1989, when Marilou was nine years old. The prosecution’s evidence detailed that during this first incident, the accused-appellant, after disrobing and threatening his daughter, succeeded in having carnal knowledge of her. The remaining sixteen counts (Criminal Case Nos. 96-877 to 96-892) were alleged to have occurred weekly in December 1995. Marilou testified that she was raped four times in the first week, four times in the second, five times in the third, and four times in the fourth week, all within their family home.
The Regional Trial Court convicted the accused-appellant on all seventeen counts and imposed the death penalty for each. The case was elevated to the Supreme Court for automatic review. The defense relied on bare denials, suggesting the complaints were motivated by the victim’s jealousy over a half-sibling. Notably, the prosecution did not formally offer in evidence a letter where the accused-appellant appeared to admit to his daughter’s allegations.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt for all seventeen counts of rape.

RULING

The Supreme Court modified the trial court’s decision. It upheld the conviction for the single count of statutory rape in Criminal Case No. 96-876. The Court found Marilou’s testimony regarding the 1989 incident to be credible, clear, and convincing, satisfying the required quantum of proof. The accused-appellant’s paternity and the victim’s age (under twelve) at the time established the elements of statutory rape. For this count, the penalty was reduced from death to reclusion perpetua, and the accused was ordered to pay civil indemnity and moral damages.
However, the Court acquitted the accused-appellant of the sixteen counts alleged to have occurred in December 1995. It ruled that the victim’s testimony for these charges was overly generalized and lacked the specific details necessary to prove each distinct crime of rape beyond reasonable doubt. Her bare statement that she was raped a certain number of times per week, without particularized accounts of the individual acts, was deemed grossly insufficient to sustain multiple convictions. The prosecution’s failure to provide corroborative evidence for these specific charges warranted acquittal based on reasonable doubt.