GR 140011; (March, 2001) (Digest)
G.R. Nos. 140011-16; March 12, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUSTAQUIO “TAQUIO” MORATA Y BIDOL, accused-appellant.
FACTS
Accused-appellant Eustaquio Morata was charged with six counts of rape against his 11-year-old sister-in-law, Marites Alamani. The Regional Trial Court convicted him for two counts (Criminal Case Nos. RTC’98-220 and RTC’98-224) and acquitted him for four. The prosecution’s evidence for the April 1997 incident (Case No. 220) detailed that Morata, by means of force and intimidation, undressed the victim, gagged her with a handkerchief, and had carnal knowledge with her. For the June 9, 1997 incident (Case No. 224), the prosecution alleged he entered her bedroom at midnight and again forced himself on her. The defense consisted of denial and alibi, claiming he was asleep during those times and attributing the acts to another brother-in-law.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the two counts of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction for Criminal Case No. RTC’98-220 but acquitted him for Criminal Case No. RTC’98-224. For the April 1997 rape, the Court found the victim’s testimony credible, straightforward, and consistent. The defense of denial could not prevail over her positive identification. The Court also noted that the victim’s failure to shout was reasonable given her age, the intimidation employed, and the accused’s position of moral ascendancy as a brother-in-law living in the same house. However, for the June 9, 1997 incident, the Court ruled that the prosecution failed to meet the burden of proof. The Information for this charge was defective for failing to specify the time with sufficient certainty, alleging only “midnight,” which deprived the accused of the opportunity to prepare a proper defense. Furthermore, the victim’s testimony for this specific instance was deemed vague and lacking in the requisite factual detail to establish the elements of rape beyond reasonable doubt. The penalty of reclusion perpetua for the sustained conviction was affirmed. The award of civil indemnity was increased to P50,000.00, and moral damages of P50,000.00 were additionally awarded, in line with prevailing jurisprudence.