GR 137993; (April, 2002) (Digest)
G.R. No. 137993 . April 11, 2002.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO SANTOS Y LABAY, accused-appellant.
FACTS
The accused-appellant, Romeo Santos, was charged with the rape of his six-year-old granddaughter, Julie Ann Gutierrez, in Pasig City in December 1997. The prosecution established that Santos brought the minor to his house, undressed her, and had carnal knowledge. The child testified to the act and the pain it caused. Her mother later discovered physical signs of abuse, including blood and secretions, and the child suffered from nightmares. A medical examination at the Philippine General Hospital confirmed vaginal lacerations consistent with penetration. The information alleged the qualifying circumstance of relationship, the accused being the victim’s grandfather.
The accused denied the charge, claiming it was fabricated by his daughter due to anger and implicating a relative, Roland Macasinag, as having instigated the complaint. The Regional Trial Court found the accused guilty beyond reasonable doubt of rape qualified by relationship and sentenced him to death, ordering him to pay civil indemnity and moral damages.
ISSUE
Whether the conviction of the accused-appellant for the crime of rape is supported by proof beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of witnesses, particularly the victim’s clear, spontaneous, and straightforward testimony, which was consistent with medical findings. The defense of denial and alleged fabrication could not prevail over the positive identification and the categorical testimony of the child victim. The Court reiterated the doctrine that the trial court’s findings on credibility are entitled to great respect, absent any showing of overlooked facts or circumstances.
The crime was correctly qualified under Article 266-B of the Revised Penal Code, as amended by R.A. No. 8353 , due to the victim’s minority (below seven years old) and her relationship to the offender within the third civil degree of consanguinity. These circumstances warranted the imposition of the death penalty, which the Court affirmed, while noting the separate opinions on the constitutionality of the death penalty law. The Court modified the awarded damages, increasing the civil indemnity to Seventy-Five Thousand Pesos (P75,000.00) and moral damages to Fifty Thousand Pesos (P50,000.00) in line with prevailing jurisprudence. The records were ordered transmitted to the Office of the President pursuant to Article 83 of the Revised Penal Code.