G.R. Nos. 136317-18, November 22, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO YAOTO, accused-appellant.

FACTS

Accused-appellant Eduardo Yaoto was charged with two counts of rape committed against his 17-year-old daughter, Angeline Yaoto, on June 2 and June 7, 1997, in Valenzuela, Metro Manila. The prosecution evidence established that in the first incident, Eduardo tied Angeline’s hands to a sofa, undressed her, and forcibly had carnal knowledge. He threatened her to keep silent. In the second incident, he again tied her, raped her, and later fell asleep with a bolo beside him, allowing Angeline to escape and report to the police. A medico-genital examination confirmed lacerations and contusions consistent with sexual and physical assault. The defense presented denial, claiming the charges were fabricated due to Angeline’s resentment over his disapproval of her boyfriend and her elopement. The trial court convicted Eduardo of two counts of qualified rape and imposed the death penalty for each count.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant of qualified rape and imposing the death penalty, particularly concerning the credibility of the complainant’s testimony and the sufficiency of the allegations in the informations.

RULING

The Supreme Court affirmed the conviction but modified the penalties. The Court found Angeline’s testimony credible, straightforward, and consistent. It rejected the accused-appellant’s arguments on physical improbabilities as trivial details that do not undermine the core narrative of forcible submission. The medical findings corroborated her account. However, the Court modified the conviction from qualified to simple rape. While the victim’s minority (17 years old) was alleged in the informations, the qualifying circumstance of relationship (that the offender is the parent of the victim) was not specifically stated. For a conviction of qualified rape under Article 335 of the Revised Penal Code, as amended, both minority and relationship must be expressly alleged to afford the accused his constitutional right to be fully informed of the nature of the accusation. Due to this fatal omission, the crime is simple rape, punishable by reclusion perpetua for each count. The Court affirmed the award of P50,000 civil indemnity per count and added P50,000 moral damages per count, but exemplary damages were not awarded due to the absence of the qualifying allegation.