GR 133922; (February, 2001) (Digest)
G.R. No. 133922 February 12, 2001
People of the Philippines, plaintiff-appellee, vs. Deolito Optana, accused-appellant.
FACTS
Accused-appellant Deolito Optana, the common-law husband of the victim’s mother, was charged with four counts of rape and four counts of child abuse under Republic Act No. 7610. The victim, Maria Rizalina Onciano, was between 11 and 13 years old during the incidents in 1993 and 1995. She testified that Optana, using force, intimidation, and threats, sexually assaulted her on multiple occasions when her mother was not at home. The defense consisted of denial and alibi, claiming the charges were fabricated due to a family quarrel. The Regional Trial Court convicted Optana on all counts, imposing penalties including reclusion perpetua for rape and awarding damages.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of rape and violation of R.A. No. 7610 beyond reasonable doubt.
RULING
The Supreme Court affirmed the convictions with modifications to the damages awarded. The Court found the victim’s testimony to be credible, consistent, and candid, detailing the assaults with the unembellished manner typical of a young victim. Her failure to immediately report the abuse was reasonably explained by her fear of the accused, who exercised moral ascendancy and dominion over her as a stepfather figure in the household. The defense of denial and alibi cannot prevail over the positive and credible identification by the victim. Regarding the charges under R.A. No. 7610, the Court clarified that the law applies to all acts of sexual abuse against children, not just commercial exploitation. The accused’s acts, committed with lewd design and through coercion and intimidation, squarely constitute child abuse under Section 5(b) of the law. The penalties imposed by the trial court were upheld. However, the awards of damages were modified in line with prevailing jurisprudence: civil indemnity of P50,000 and moral damages of P50,000 were sustained for the relevant cases, but the award of exemplary damages was deleted for lack of legal basis.