G.R. Nos. 146464-67 November 15, 2002
People of the Philippines, plaintiff-appellee, vs. Jose Villanueva, accused-appellant.

FACTS

Four Informations were filed before the Regional Trial Court of Legazpi City charging Jose Villanueva with rape committed against his daughter, Gina Villanueva. The charges were: (1) on October 8, 1995, by means of force, threat, and intimidation; (2) sometime in September 1995, by poking a knife at her, undressing her, and having carnal knowledge; (3) sometime in August 1995, while she was sleeping or otherwise unconscious; and (4) on April 18, 1998, by means of force, threat, and intimidation. The cases were consolidated. At arraignment, Jose pleaded not guilty. The prosecution presented Gina, who testified in detail about the four incidents of rape, describing force, threats with a knife, and being rendered unconscious on one occasion. She reported the incidents to her mother, who did nothing due to fear, and later escaped to report the rapes to her uncle and grandfather, leading to an NBI complaint. Her testimony was corroborated by her sister Vilma, who testified that she and another sister were also raped by their father, and by the medico-legal findings of healed hymenal lacerations. The defense presented Gina’s mother and other sisters, who denied the rapes and claimed Gina left home because her father was strict and was instigated by her grandfather to file the case. The trial court convicted Jose Villanueva of four counts of rape and imposed the death penalty for each count.

ISSUE

Whether the guilt of accused-appellant Jose Villanueva for the crime of rape was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The Court found Gina’s testimony to be credible, straightforward, and consistent. The defense of denial and alibi could not prevail over her positive identification. The Court noted that in incestuous rape, the victim’s testimony is accorded greater weight, as an offspring would not accuse a parent of a serious crime without a compelling reason. The medico-legal findings of healed lacerations corroborated her claim of prior sexual intercourse. The defense witnesses’ testimonies were deemed biased and insufficient to overcome the prosecution’s evidence. The Court held that all elements of rape were properly alleged and proved. The penalty of death was affirmed due to the qualifying circumstance of the victim being under eighteen and the offender being a parent. The awards of civil indemnity and moral damages were affirmed, and exemplary damages were increased to P25,000 per case.