G.R. Nos. 135554-56; June 21, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO DELA CRUZ y CARIZZA, accused-appellant.

FACTS

Accused-appellant Danilo dela Cruz was charged with two counts of rape and one count of acts of lasciviousness against his daughter, Jeannie Ann. The first rape allegedly occurred in September 1990 when Jeannie Ann was 11 years old, and the second in July 1995 when she was 16. A third information, under Republic Act No. 7610, was filed for acts committed in August 1997. The prosecution established that the accused-appellant, a teacher, began molesting his daughter when she was seven, performing sexual acts and issuing threats to ensure her silence. Jeannie Ann testified in detail about the specific incidents of abuse, supported by her mother’s testimony and medico-legal findings.
The defense interposed denial and alibi, claiming he was in Tarlac during the alleged incidents and could not have been in Baguio. He argued that the charges were fabricated due to family discord. The Regional Trial Court of Baguio City found him guilty of two counts of rape and one count of acts of lasciviousness, sentencing him to death for each rape count. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of rape and acts of lasciviousness beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The Court found the testimony of the victim, Jeannie Ann, to be credible, consistent, and corroborated by medical evidence. The defense of denial and alibi cannot prevail over the positive identification and detailed narration of the victim. For the rape committed in 1990, the penalty was reclusion perpetua, as the death penalty under the old law required force, intimidation, or the victim’s unconsciousness, which was not sufficiently proven for that specific incident. For the 1995 rape, where force and intimidation were alleged and proven, the death penalty was proper under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, due to the father-daughter relationship. However, with the enactment of R.A. No. 9346 prohibiting the death penalty, the sentence was reduced to reclusion perpetua without parole. The conviction for acts of lasciviousness under R.A. No. 7610 was also affirmed. The Court emphasized that the victim’s credibility remained intact despite delayed reporting, as the threats and psychological control exerted by a parent explain the silence.