GR 145172; (February, 2003) (Digest)
G.R. Nos. 145172-74; February 28, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IRENEO CORRAL, accused-appellant.
FACTS
Ireneo Corral was convicted by the Regional Trial Court of two counts of rape and one count of acts of lasciviousness against his 12-year-old stepdaughter, Jobell B. Galang. The acts of lasciviousness occurred in May 1994, while the two rapes transpired in November 1996, prior to and on November 30, 1996. The prosecution established that the appellant used a knife or balisong to threaten the victim, employed force by slapping her, and took advantage of her while she slept in their shared shanty. The victim reported the incidents almost a year after the last rape. The defense, primarily through the testimony of the victim’s mother, Amalia Galang, claimed the allegations were fabricated and that no unusual behavior was observed in the victim, arguing the incidents were impossible given their living arrangements.
ISSUE
The core issue is whether the prosecution proved the guilt of the appellant for the crimes of rape beyond reasonable doubt, particularly considering the victim’s delayed reporting and the defense of alibi and denial.
RULING
The Supreme Court affirmed the conviction for two counts of rape but reduced the penalty from death to reclusion perpetua for each count, as the requisite qualifying circumstance of the victim’s minority was not properly alleged in the informations. The Court upheld the trial court’s assessment of the victim’s credibility. Delay in reporting a rape, especially when the offender is a relative living in the same household who issues threats against the victim’s family, does not undermine credibility but is understandable. The victim’s candid and consistent testimony, corroborated by the medico-legal findings of healed lacerations consistent with sexual intercourse, constituted proof beyond reasonable doubt. The defense of denial and alibi, unsupported by clear and convincing evidence, cannot prevail over the positive identification by the victim. The Court modified the awards, ordering the appellant to pay the victim P50,000.00 as civil indemnity and P50,000.00 as moral damages for each count of rape.