G.R. No. 144305 -07. February 6, 2003.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TACIO EMILIO y INTE, accused-appellant.

FACTS

The accused-appellant, Tacio Emilio, was convicted by the Regional Trial Court for three counts of rape against his minor stepdaughter, Maria Teresa Eslao. The incidents occurred in October 1995 and October 1996 in Sablan, Benguet. The victim, who was 11 and 12 years old at the times of the assaults, testified that her stepfather sexually assaulted her by means of force and intimidation while her mother was working abroad. She detailed how he would approach her as she slept, pull down her clothing, and consummate the act despite her resistance and crying. The victim initially kept silent out of fear but eventually disclosed the rapes to her grandmother and uncles after the third incident in October 1996, leading to a medical examination and the filing of criminal complaints.
The defense relied on denial and alibi, claiming the charges were fabricated due to family resentment. The trial court, however, found the victim’s testimony credible, straightforward, and consistent, and convicted Emilio, imposing the death penalty for each count. The case was automatically elevated to the Supreme Court for review.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that the victim’s testimony, given in a categorical, consistent, and straightforward manner, was sufficient to establish the elements of rape. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and the testimony of a young victim, when credible, deserves full weight. The victim’s detailed account of the assaults, her immediate disclosure to relatives, and the medico-legal findings of a lacerated hymen corroborated her claims. The Court found no ill motive for the minor to falsely accuse her stepfather.
The defense of denial and alibi was deemed inherently weak and could not prevail over the positive identification and credible testimony of the victim. The Court also ruled that the qualifying circumstance of relationship (stepfather-stepdaughter) and the victim’s minority (13 years old at the time of the filing of the informations) were duly proven, warranting the imposition of the death penalty under the applicable law, Republic Act No. 7659 . The penalty was affirmed, subject to automatic review by the Office of the President, and exemplary damages were awarded to the victim.