G.R. No. 133194-95 and 141539; January 29, 2004
PEOPLE OF THE PHILIPPINES, Appellee, vs. ROMEO VALDEZ, Appellant.

FACTS

Appellant Romeo Valdez was charged with three counts of rape against his daughter, Romela M. Valdez. The incidents occurred in 1992 and 1993 at their residence in Masbate. In the first incident (Criminal Case No. 7177), Romela, after consuming a soft drink served by her father, became dizzy, fell asleep, and awoke to find herself naked with appellant, noticing blood on her sheets. In the second incident (Criminal Case No. 7178), appellant, armed with a handgun, forced her from the bathroom, physically assaulted her, and raped her. In the third incident (Criminal Case No. 7176), appellant again used a gun to threaten her into submission and raped her. Romela did not immediately report the rapes due to appellant’s threats to kill her and his claims of influence with local officials. She eventually escaped to Manila and disclosed the crimes to her aunt, leading to the filing of charges.
The Regional Trial Court convicted Valdez in Criminal Case Nos. 7176 and 7178 but acquitted him in Criminal Case No. 7177, finding insufficient evidence that a drug was used. The court sentenced him to reclusion perpetua for each conviction. On appeal, Valdez argued that the testimonies were inconsistent and that the medical certificate did not prove loss of virginity due to the rapes, suggesting Romela’s prior sexual activity.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Romeo Valdez for the crimes of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions. The Court held that Romela’s testimony was credible, straightforward, and consistent on the material points of the rapes. Minor inconsistencies regarding peripheral details, such as the exact dates, do not undermine credibility but instead indicate an unrehearsed narration. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi presented by Valdez was weak and uncorroborated.
Regarding the medical findings, the Court ruled that the absence of fresh lacerations does not negate rape, as medical examination was conducted long after the incidents. The old, healed lacerations documented were consistent with her testimony of prior sexual violation. The element of force and intimidation was conclusively established by appellant’s use of a handgun and threats to kill Romela, which instilled fear and rendered resistance futile. The Court modified the awards of civil indemnity and moral damages to conform with prevailing jurisprudence but upheld the penalties of reclusion perpetua for each count of rape.