GR 138364; (October, 2003) (Digest)
G.R. No. 138364; October 15, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ROGELIO VILLANUEVA, appellant.
FACTS
Appellant Rogelio Villanueva was charged with raping his fifteen-year-old daughter, Reseilleta. On December 12, 1996, after sending his other daughters to do laundry, appellant ordered Reseilleta to stay. He dragged her, poked a knife, and struck her with an iron bar and his fist, causing her to faint. Upon regaining consciousness, she felt pain and found her genitalia bleeding. Reseilleta fled to her uncle’s house. Later, her younger sister, Mary Joy, reported appellant’s attempted sexual abuse to their mother, Estelita. This prompted Estelita to seek out Reseilleta, who confirmed the rape. A medical examination revealed a healed hymenal laceration.
Appellant denied the accusation, claiming he was at a farm all day and that the charge was instigated by his wife to counter his plan to file abandonment charges. The trial court found him guilty of qualified rape and imposed the death penalty, prompting this automatic review.
ISSUE
The core issues were whether the trial court erred in finding appellant guilty beyond reasonable doubt and in imposing the death penalty.
RULING
The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such findings are accorded great respect. It rejected appellant’s argument that Reseilleta’s unconsciousness during the assault rendered her testimony unreliable. The Court reasoned that her testimony about events before and after losing consciousness was consistent and credible, and her immediate flight and subsequent report corroborated her account. The medical finding of a healed hymenal laceration, while not conclusive of recent penetration, supported her claim of prior sexual abuse.
However, the Court found the victim’s minority was not proven with the required certainty. The prosecution presented conflicting evidence regarding her exact age. Consequently, the qualifying circumstance of minority could not be appreciated. Only the qualifying circumstance of relationship was established. Therefore, the crime was simple rape, not qualified rape punishable by death. Appellant was sentenced to reclusion perpetua and ordered to pay Reseilleta P50,000 as civil indemnity and P50,000 as moral damages.