GR 142602; (October, 2001) (Digest)
G.R. Nos. 142602-05; October 3, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO ARIOLA, accused-appellant.
FACTS
Accused-appellant Bonifacio Ariola was charged with four counts of rape committed against his daughter, Maribel Ariola, on December 16-19, 1994, in Santiago City, Isabela. The prosecution evidence established that during those dates, Maribel was alone in their one-room house with her father. She testified that on each occasion, her father kissed her, used force and intimidation, and had carnal knowledge of her against her will. She did not immediately report the incidents due to fear, only disclosing them to her mother in March 1997. Medical examination revealed old hymenal lacerations, but the physician could not definitively conclude they were caused by sexual intercourse.
The defense consisted solely of accused-appellant’s denial. He claimed the charges were fabricated because he wanted to separate from his wife and because he had whipped Maribel for disobedience. He admitted being alone with Maribel in their one-room house on the alleged dates but denied committing the acts.
ISSUE
Whether the guilt of accused-appellant for four counts of rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction but modified the penalty. The Court found Maribel’s testimony to be credible, straightforward, and consistent. Delay in reporting rape, especially when the offender is a parent, does not undermine credibility, as fear and intimidation are natural consequences. The medical findings, while inconclusive, were consistent with her account. The defense of denial, uncorroborated and inherently weak, cannot prevail over the positive and categorical testimony of the victim. The relationship of father and daughter, which was admitted, bolstered the credibility of the charge, as it is highly improbable for a daughter to accuse her father falsely of a crime that brings stigma to herself and her family.
However, the Court modified the penalty. The trial court imposed death, but the Supreme Court held that the qualifying circumstance of relationship, while proven, was not alleged in the informations. Consequently, the crime is simple rape, punishable by reclusion perpetua. The award of civil indemnity was affirmed at P50,000.00 per count, and moral damages of P50,000.00 per count were additionally awarded, as moral suffering is presumed in rape cases.