G.R. Nos. 148139-43; October 15, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. HERMENIO (HERMINIO) CANOY, appellant.

FACTS

The appellant, Hermenio Canoy, was charged with multiple counts of rape and acts of lasciviousness against his daughter, Den Canoy. The incidents spanned several years, beginning in 1994 when Den was a child. The prosecution detailed specific instances of abuse, including the insertion of a finger into her vagina in 1994, an attempted rape in April 1998, and completed rapes in the summer of 1996, on May 31, 1998, and on February 20, 1999. Den testified to the repeated assaults, her fear of her violent father, and her mother’s initial inaction. Medical examination confirmed hymenal lacerations consistent with sexual intercourse. The defense relied on denial and alibi, claiming the charges were fabricated.

ISSUE

The core issue was whether the prosecution proved the guilt of the appellant for the crimes of rape and acts of lasciviousness beyond reasonable doubt.

RULING

The Supreme Court affirmed the appellant’s conviction. The Court found Den’s testimony to be credible, straightforward, and consistent, even enduring rigorous cross-examination. The medical findings corroborated her account of sexual abuse. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi, unsubstantiated by clear and convincing evidence, could not prevail over the positive identification and detailed narration of the victim. The relationship of father and daughter, which qualified the rapes, was sufficiently established. The Court also noted the victim’s natural reluctance to immediately report the crimes due to fear and familial pressure, which did not undermine her credibility but instead made her account more believable. Consequently, the penalties and awards for damages were upheld with modifications, including the imposition of the death penalty for the qualified rape charges, subject to review for executive clemency.