G.R. Nos. 146097-98; August 26, 2003
PEOPLE OF THE PHILIPPINES, Appellee, vs. JUAN CARIÑAGA, Appellant.

FACTS

Appellant Juan Cariñaga was charged with two counts of qualified rape against his 12-year-old daughter, Venilda. The first incident allegedly occurred on November 23, 1998, at around 5:00 a.m., inside their one-room house in Ligao, Albay. Venilda testified that her father returned home, turned off the light, and sexually assaulted her while threatening to kill the family if she told anyone. The second incident allegedly happened on December 15, 1998, at around 5:00 p.m., under similar circumstances. Venilda’s younger sister, Belinda, partially witnessed the first assault. The defense presented alibi, claiming the appellant was elsewhere during the alleged incidents, and argued that the charges were fabricated due to family resentment.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the guilt of the appellant for two counts of qualified rape, warranting the imposition of the death penalty.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty for each count. The Court found Venilda’s testimony to be credible, straightforward, and consistent, even under rigorous cross-examination. The testimony of a minor victim, when credible, is sufficient to sustain a conviction for rape. The defense of alibi was rejected as inherently weak and could not prevail over the positive identification by the victim. The relationship of father and daughter, which was judicially admitted, qualified the rapes under Article 266-B of the Revised Penal Code, making the death penalty applicable. The Court modified the damages, awarding civil indemnity, moral damages, and exemplary damages for each count. The decision was subject to automatic review for the possible exercise of executive clemency.