GR 137660; (March, 2001) (Digest)
G.R. No. 137660 . March 28, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS L. ALCANTARA, accused-appellant.
FACTS
Rosalie Gonzales, a Grade 5 student, accused her stepfather, Carlos L. Alcantara, of raping her multiple times from 1988, when she was six years old, until November 19, 1991. The abuse occurred at night while other family members slept, with Alcantara covering her mouth and threatening to kill her if she reported the incidents. Rosalie only disclosed the abuse to her mother, Salvacion, in 1994 after learning that Alcantara also threatened her sister, Daisy.
A medical examination on October 13, 1994, by Dr. Salve Sapinoso revealed old hymenal lacerations and a vaginal opening that admitted two fingers freely, findings compatible with penile penetration. An Information for rape was subsequently filed. The Regional Trial Court convicted Alcantara of rape and sentenced him to reclusion perpetua and indemnity. Alcantara appealed, arguing his guilt was not proven beyond reasonable doubt.
ISSUE
Whether the guilt of accused-appellant Carlos L. Alcantara for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Rosalie, to be credible, straightforward, and consistent. It held that in rape cases, the credibility of the complainant is paramount, and her testimony, if credible, is sufficient to sustain a conviction. The medical findings corroborated her account of sexual abuse. The Court rejected Alcantara’s defenses as self-serving and unsubstantiated.
His denial cannot prevail over Rosalie’s positive identification. The claim that the crime was improbable because other siblings were present was dismissed, as rape can be committed even in such circumstances, especially when intimidation is employed. The Court also found the alleged motive of jealousy by his wife to be unnatural and unworthy of belief, as no mother would subject her daughter to the ordeal of a rape trial out of mere spite. The trial court’s decision was affirmed with modification, ordering Alcantara to pay an additional P50,000.00 as moral damages, which is automatically granted in rape cases without need of further proof.