G.R. No. 142873 ; July 9, 2002
PEOPLE OF THE PHILIPPINES, appellee, vs. MAXIMO SALVADOR, appellant.

FACTS

This is an automatic review of the death penalty imposed by the Regional Trial Court of Cagayan de Oro City. Appellant Maximo Salvador was convicted of qualified rape for sexually assaulting his 14-year-old daughter, Merlyn Salvador. The prosecution evidence established that on December 3, 1998, the victim was instructed by her father to nap inside their bedroom. Upon waking, she found herself naked, with her father embracing her. He pinned her hands, inserted his penis into her vagina, and made pumping motions, causing her extreme pain. He later ejaculated and threatened to kill her and her family if she reported the incident. In January 1999, he attempted another assault but desisted when she shouted. The victim eventually fled home and later disclosed the rape to an uncle, leading to a medical examination that revealed old healed lacerations consistent with sexual trauma.
During trial, the appellant pleaded not guilty and assailed the credibility of the victim’s testimony, arguing it defied human experience. He contended the prosecution failed to prove his guilt beyond reasonable doubt, emphasizing that the medical findings were inconclusive. He further argued that even if guilty, the death penalty was improperly imposed as the alleged qualifying circumstances were not sufficiently proven. The trial court, however, found the victim’s testimony credible and convicted the appellant of qualified rape, sentencing him to death and ordering him to pay indemnity and damages.

ISSUE

The core issues are: (1) whether the prosecution proved the appellant’s guilt for rape beyond reasonable doubt, and (2) whether the imposition of the death penalty was proper under the circumstances.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. On the first issue, the Court meticulously applied the guiding principles in reviewing rape cases: accusations are easy to make but hard to disprove; a complainant’s testimony must be scrutinized with extreme caution; and the prosecution’s case must stand on its own merits. The Court found the victim’s testimony to be credible, straightforward, and replete with convincing details. She consistently described the forcible sexual intercourse, the pain, the threat, and her subsequent escape. Her testimony was corroborated by the medical finding of old healed lacerations. The Court emphasized that when a rape victim, especially a minor, gives a credible account of the violation, her testimony alone can suffice for conviction, particularly when the accused is a parent. The appellant’s denial and attacks on credibility were unavailing against the clear and positive testimony.
On the second issue, the Court held the death penalty was correctly imposed. The Information alleged and the evidence proved the qualifying circumstance of relationship—the appellant is the legitimate father of the victim, who was under eighteen years old at the time of the rape. Under Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8353 , rape is qualified and punishable by death when the victim is under eighteen and the offender is a parent. The victim’s birth certificate conclusively established both her minority and her filiation to the appellant. No other aggravating circumstance needed to be proven. Thus, the penalty of death was mandatory. The Court also affirmed the awards of ₱75,000 as civil indemnity and ₱50,000 as moral damages, which are standard in rape convictions.