G.R. No. 137978-79, November 22, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PFC. HECTOR C. SALE, accused-appellant.

FACTS

Accused-appellant Pfc. Hector C. Sale was charged with two counts of rape against his minor daughter, Helen Grace M. Sale. The first incident allegedly occurred on June 12, 1995, at their bunkhouse in Camp Evangelista, Cagayan de Oro City. The prosecution evidence showed that Helen Grace, then 14 years old, was sleeping when her father, taking advantage of his moral ascendancy, forcibly had carnal knowledge with her, threatening her with a hand grenade afterward. The second incident was alleged to have occurred on February 8, 1997, under similar circumstances, with the accused-appellant threatening her with a knife. The victim reported the rapes to her cousin and mother in February 1997, leading to a medical examination and the filing of criminal complaints.
The defense interposed denial and alibi. Accused-appellant claimed he was on duty or elsewhere during the alleged incidents. He argued that the charges were fabricated due to family resentment, alleging that Helen Grace’s mother influenced her to file the case after he refused to give them money. The trial court rejected the defense, finding the victim’s testimony credible and consistent, and convicted the accused-appellant of two counts of qualified rape.

ISSUE

Whether the trial court erred in convicting accused-appellant of two counts of qualified rape and imposing the death penalty based on the credibility of the victim’s testimony and the presence of qualifying circumstances.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty for each count of rape. The Court upheld the trial court’s assessment of the victim’s credibility, noting that her testimony was straightforward, candid, and consistent even under rigorous cross-examination. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi, being inherently weak, could not prevail over the positive identification and detailed account provided by the victim.
The legal logic for affirming the death penalty rests on the presence of qualifying circumstances under Article 335 of the Revised Penal Code, as amended by R.A. 7659. The rape was qualified because the victim was under eighteen years of age at the time of the commission, and the offender was the parent of the victim. These twin circumstances were duly alleged in the informations and proven during trial. The Court found no reason to deviate from the factual findings of the trial court, which are accorded high respect. The awards of civil indemnity and moral damages were also affirmed as mandatory in cases warranting the death penalty.