G.R. No. 131848-50; September 5, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO VILLARAZA Y PANIS, accused-appellant.

FACTS

The accused-appellant, Rodolfo Villaraza y Panis, was convicted by the Regional Trial Court of Naga City for three counts of rape against his eleven-year-old stepdaughter, Jennifer Garcia, and was sentenced to death for each count. The informations alleged that the rapes occurred on February 21, February 26, and March 1, 1997, in Barangay Bell, Magarao, Camarines Sur. The prosecution established that the accused, who was cohabiting with the victim’s mother, Wenifreda Garcia, committed the acts through force and intimidation. The victim’s credible testimony, corroborated by her mother’s account of the disclosure and a medical certificate, formed the core of the evidence against the appellant.
During trial, Jennifer Garcia provided a detailed and consistent narration of the sexual assaults. The defense interposed denial and alibi, which the trial court found unconvincing. The court gave full credence to the victim’s testimony, noting its categorical and straightforward nature. Consequently, the trial court found the accused guilty beyond reasonable doubt for three counts of qualified rape, imposing the supreme penalty of death in each case, premised on the qualifying circumstance of the accused being the stepfather of the victim.

ISSUE

Whether the trial court correctly convicted the accused of three counts of qualified rape punishable by death.

RULING

The Supreme Court affirmed the conviction for three counts of rape but modified the penalty from death to reclusion perpetua for each count. The Court upheld the factual findings of the trial court, emphasizing that the victim’s testimony was credible, unshaken, and sufficient to sustain a conviction. The Court reiterated the doctrine that in rape cases, the complainant’s testimony, if credible, is enough to convict.
However, the Court reduced the penalty due to a fatal flaw in the informations. For the death penalty to be imposed under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, the qualifying circumstance of relationship must be accurately alleged. The informations described the accused as the “stepfather” of the victim. Legally, a stepfather-stepdaughter relationship requires a legitimate marital bond between the accused and the victim’s parent. The evidence showed that the victim’s mother, Wenifreda Garcia, was lawfully married to another man, Benjamin Garcia, from whom she had separated. Since the accused was merely cohabiting with Wenifreda, the legal relationship of stepfather-stepdaughter did not exist. This failure to accurately allege a qualifying relationship barred the imposition of the death penalty. Thus, the crime is simple rape, punishable by reclusion perpetua. The Court also increased the award of civil indemnity to P50,000.00 for each count and affirmed the award of moral damages.