G.R. No. 134566 -67, January 22, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GONYETO FRANCISCO y CAPELLAN, accused-appellant.

FACTS

Accused-appellant Gonyeto Francisco was charged with two counts of rape against his stepdaughter, Wennie Merioles (16 years old), and his daughter, Rachelle Francisco (13 years old). The incidents occurred in July 1996 in Rosario, Cavite. In Criminal Case No. 248-96, Francisco, taking advantage of being home due to rheumatism, summoned Wennie and threatened to kill her if she did not submit to his sexual advances, leading to intercourse. In Criminal Case No. 249-96, he ordered Rachelle’s younger siblings out of the house, intimidated Rachelle into undressing, and proceeded to have carnal knowledge with her. The victims revealed the abuses to their mother days later, leading to medical examinations which, for Wennie, showed old healed hymenal lacerations and, for Rachelle, an intact but distensible hymen.
The Regional Trial Court convicted Francisco of two counts of rape and imposed the death penalty. The case was elevated to the Supreme Court for automatic review, with the defense arguing the testimonies were incredible and the medical findings did not prove recent penetration.

ISSUE

Whether the guilt of the accused-appellant for two counts of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of the victims’ credibility, noting their candid and consistent testimonies detailing the force, intimidation, and moral ascendancy employed by their father/stepfather. The defense of denial and alibi was weak and uncorroborated. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The medical findings, while not indicating fresh injuries for Rachelle, were consistent with sexual abuse given her age and the distensible nature of her hymen. However, the Court modified the penalty. For the rape of Rachelle, a minor under 18 and a daughter, the death penalty under Article 335 of the Revised Penal Code was applicable. For the rape of Wennie, a stepdaughter, the qualifying circumstance of relationship under Article 335 was inapplicable as she was not a legitimate, illegitimate, or adopted daughter. Thus, the crime was simple rape, punishable by reclusion perpetua. Applying the ruling in People v. Echegaray, the death penalty for Rachelle’s rape was reduced to reclusion perpetua due to the passage of Republic Act No. 9346 . The Court awarded civil indemnity, moral damages, and exemplary damages to each victim.