G.R. No. 137745 ; February 15, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO TAGUN, accused-appellant.

FACTS

The accused-appellant, Reynaldo Tagun, was charged with the rape of his five-year-old daughter, Charity Tagun, committed in Lucena City between December 1991 and December 1992. The prosecution presented Charity, who testified that her father, whom she called “papa,” inserted his penis into her vagina on one occasion at her grandmother’s house, causing her pain and bleeding. Charity’s mother, Norily, learned of the incident during a vacation in December 1992 after Charity directly informed her. Norily had Charity medically examined by Dr. Maricel P. Rivera, whose findings revealed a “deep healed hymenal laceration” consistent with penetration. After confronting the appellant, who threatened her and Charity, Norily eventually reported the crime in May 1993.
The defense presented an alibi, claiming appellant was in Hong Kong during the alleged period. Appellant, along with his sister Lourdes and mother Gregoria, testified that Charity’s vaginal injuries were caused by her uncle, Isyo, in November 1992. They stated they informed appellant, who then returned to the Philippines to fetch Charity. The defense argued that the charge was fabricated by Norily due to marital discord.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape has been proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Charity, to be credible, straightforward, and consistent. As a child of tender age, her testimony was given full credence, especially as it was corroborated by the medical findings of Dr. Rivera, which objectively confirmed sexual abuse. The Court emphasized that the testimony of a young rape victim, when credible, is sufficient to sustain a conviction.
The defense of alibi was rejected as inherently weak and unsubstantiated. It was established mainly by the accused and his relatives, whose testimonies were deemed insufficient to overthrow the positive identification by the victim. The Court also noted that the alleged motive for fabrication—marital strife—was not convincingly proven. The trial court’s factual findings on credibility are accorded great respect. However, the Court modified the civil liability by ordering the appellant to pay the victim ₱50,000.00 as civil indemnity, which is mandatory upon a finding of rape, in addition to the moral and exemplary damages awarded by the trial court.