G.R. Nos. 135524-25; September 24, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANOLITO AGUSTIN, accused-appellant.
FACTS
The case involves two counts of incestuous rape committed by accused-appellant Manolito Agustin against his 14-year-old daughter, Marina Agustin. The first incident occurred on February 12, 1997, in their home in Paniqui, Tarlac. Marina testified that while she was alone cleaning, her father arrived, forced her onto a papag, removed her clothing and his own, and had carnal knowledge with her despite her pleas. He then threatened to kill her if she reported it. The second rape happened on February 16, 1997, when Manolito again found Marina alone, this time bathing, and proceeded to rape her. Afterward, Marina reported the assaults to her grandfather and a neighbor, leading to a police report and a medical examination.
At trial, the prosecution presented Marina, her grandfather, the neighbor, and the examining physician. The defense presented only Manolito, who denied the first rape, claiming he was elsewhere, but shockingly admitted to digitally penetrating his daughter on February 16. He claimed this act was driven by longing for his estranged wife and that the rape charges were fabricated by his father-in-law to seize his property. The Regional Trial Court convicted him of two counts of rape and imposed the death penalty for each, along with damages.
ISSUE
The core issues are: (1) whether the prosecution proved the guilt of the accused for two counts of rape beyond reasonable doubt, and (2) whether his admission to “fingering” should result in conviction for a lesser offense like acts of lasciviousness for the second incident.
RULING
The Supreme Court affirmed the conviction for two counts of rape but modified the damages. The Court found Marina’s testimony to be credible, straightforward, and consistent. In rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The Court rejected the appellant’s arguments regarding lack of force and the medical findings. The medical report, which indicated an elastic hymen and no fresh lacerations, did not negate rape, as it is settled that a healed hymen does not disprove sexual intercourse. The defense’s claim of fabrication was deemed implausible, as no daughter would willingly accuse her own father of a grave crime and subject herself to public scrutiny without a compelling reason.
Crucially, the Court ruled that the appellant’s judicial admission of digital penetration on February 16 did not downgrade the charge. His confession corroborated Marina’s account of a sexual assault on that date. Given the established context of force, intimidation, and paternal authority, and in line with the doctrine that rape is committed by any form of sexual penetration, his admission substantiated the charge of rape, not a lesser offense. The death penalty was affirmed as the qualifying circumstances of minority and relationship were duly alleged and proven. The Court modified the damages, awarding P75,000.00 as civil indemnity and P50,000.00 as moral damages per count, but reduced exemplary damages to P25,000.00 each.