GR 145523; (December, 2003) (Digest)
G.R. Nos. 145523-24; December 11, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. EDUARDO RATA y BAGAMENTO, appellant.
FACTS
Appellant Eduardo Rata was charged with two counts of qualified rape against his daughter, Annaliza Rata. The prosecution alleged that the rapes occurred on December 25, 1996, and October 23, 1997. Annaliza testified that her father sexually assaulted her in their home. The defense presented an alibi for the December 1996 incident, claiming appellant was preparing for a child’s baptism, and denied the October 1997 incident, suggesting the charge arose from Annaliza’s anger after being disciplined. The trial court convicted appellant of two counts of qualified rape and imposed the death penalty for each count.
ISSUE
The primary issue is whether the prosecution proved appellant’s guilt for two counts of qualified rape beyond reasonable doubt.
RULING
The Supreme Court modified the trial court’s decision. For Criminal Case No. 18753-MN (December 25, 1996), the Court acquitted appellant. The prosecution failed to establish his guilt beyond reasonable doubt. Annaliza’s testimony for this incident was deemed insufficiently detailed and credible, lacking the specific, consistent narrative required in rape cases. The defense’s alibi, corroborated by a baptismal certificate and witness testimony, created reasonable doubt.
For Criminal Case No. 18752-MN (October 23, 1997), the Court found appellant guilty only of simple rape, not qualified rape. Annaliza’s testimony for this incident was clear, convincing, and consistent. However, the prosecution failed to prove the qualifying circumstances of minority and relationship. While the Information alleged Annaliza was under 18, the prosecution did not present her birth certificate or other competent evidence to prove her age at the time of the crime. Relationship was also not conclusively established. Consequently, the crime is simple rape under Article 266-A of the Revised Penal Code, punishable by reclusion perpetua. The civil indemnity was reduced to ₱50,000, and moral damages of ₱50,000 were awarded.