GR 141136; (January, 2002) (Digest)
G.R. No. 141136 ; January 28, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NELSON PARCIA, accused-appellant.
FACTS
The prosecution alleged that in the early dawn of August 5, 1996, accused-appellant Nelson Parcia, while armed, entered the small house of Geronimo Alferez in Agusan del Sur. While Geronimo and others were drinking in the kitchen, Parcia went to the sala where 12-year-old Lorna Alferez was sleeping with her brothers. He touched her, covered her mouth, lowered her panty and his pants, and succeeded in having carnal knowledge against her will. Lorna’s brother Ricky witnessed the assault but was immobilized by fear due to Parcia’s firearm. The incident was reported the next day after a family discussion, leading to a medico-legal examination which confirmed hymenal lacerations.
The defense presented a different scenario, claiming Parcia and companions were at the Alferez house to dry copra and discuss politics. Parcia denied the rape, asserting he merely slept by the door after a drinking session. He suggested the charge was fabricated because Geronimo refused to support his barangay election bid, preferring Geronimo’s uncle instead.
ISSUE
Whether the guilt of accused-appellant Nelson Parcia for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of witnesses, particularly the victim’s clear, consistent, and candid testimony detailing the rape. The defense of denial and frame-up was rejected. The Court found it highly improbable that a father would fabricate a rape charge and subject his young daughter to the ordeal of a public trial merely due to a political disagreement. Denial, being a weak defense, cannot prevail over the positive and credible identification by the victim, who was familiar with the accused and recognized him by light from the kitchen.
The medico-legal findings, though noting an absence of sperm cells, corroborated the claim of recent sexual intercourse through the presence of hymenal lacerations and hyperemia. The Court modified the damages awarded by the trial court. In addition to the P50,000.00 civil indemnity, the Court awarded moral damages of P50,000.00, which is automatically granted in rape cases without need for further proof. The penalty of reclusion perpetua was sustained.