GR 140781; (May, 2003) (Digest)
G.R. No. 140781; May 8, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. EDUARDO METIN, appellant.
FACTS
The appellant, Eduardo Metin, was charged with the qualified rape of his 14-year-old daughter, Emelyn Metin, on December 31, 1996, in Candelaria, Quezon. The prosecution’s evidence established that Emelyn was awakened at night by the appellant caressing her. He then forced her to the floor, removed her clothing and his own, and proceeded to have carnal knowledge of her despite her pleas. He warned her to keep quiet. Emelyn did not immediately report the incident out of fear, as the appellant had a habit of brandishing a bolo when drunk. Her pregnancy was discovered seven months later, leading to the revelation of the rape. Medical examination confirmed old hymenal lacerations. The defense consisted solely of the appellant’s denial and alibi, claiming he was at a drinking session and that the accusation was fabricated by his in-laws to drive him from their home.
ISSUE
The core issues were: (1) whether the prosecution proved the crime of rape beyond reasonable doubt, and (2) whether the imposition of the death penalty was proper.
RULING
The Supreme Court affirmed the conviction but modified the penalty. On the first issue, the Court upheld the trial court’s assessment of Emelyn’s credibility. Her testimony was found to be straightforward, convincing, and consistent with human experience. No young woman would fabricate a story of rape by her own father, undergo the ordeal of a public trial, and bear a child from the assault, unless motivated by a sincere desire for justice. The appellant’s defense of alibi and denial could not prevail over the positive and categorical identification by the victim. The delay in reporting was sufficiently explained by her well-founded fear of the appellant.
On the second issue, the Court ruled that the death penalty could not be sustained. While the qualifying circumstance of the victim being a minor and the offender being her parent was alleged in the Information and proven, the prosecution failed to present the victim’s birth certificate or any similar documentary evidence to conclusively prove her minority at the time of the rape. Her oral testimony about her age, while given in court, was insufficient for the imposition of the supreme penalty. Consequently, the penalty was reduced to reclusion perpetua. The Court also modified the awards for damages, increasing the civil indemnity to P50,000 and awarding an additional P50,000 in moral damages and P25,000 in exemplary damages.