G.R. No. 166895; January 24, 2007
PEOPLE OF THE PHILIPPINES, Appellee, vs. ROMEO BUBAN, Appellant.

FACTS

Appellant Romeo Buban was charged with five counts of rape committed against his 12-year-old daughter, AAA, in June and July 1997. The prosecution alleged that the rapes occurred in their family home in Capalonga, Camarines Norte, with appellant using force, threats, and intimidation. AAA testified to the specific instances, detailing how appellant threatened her with violence, including strangulation and a knife, to ensure her silence and compliance. She reported the incidents only after confiding in her brother, leading to a barangay report and subsequent legal action. The defense presented a denial, claiming the charges were fabricated due to a family conflict.
The Regional Trial Court convicted appellant of all charges and imposed the death penalty, a decision affirmed by the Court of Appeals. The case was elevated to the Supreme Court for automatic review, given the penalty imposed. Key issues raised included the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence to establish guilt beyond reasonable doubt.

ISSUE

Whether the prosecution successfully proved the guilt of appellant Romeo Buban for the crime of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court upheld the findings of the lower courts, emphasizing that the testimony of a rape victim, especially a minor, is accorded great weight when credible and consistent. AAA’s detailed and unwavering narration of the traumatic events, including the specific threats used by her father, was deemed credible and sufficient to establish the elements of rape through force and intimidation. The Court found no ill motive for AAA to falsely accuse her own father, and her initial silence was reasonably explained by fear and the moral ascendancy and threats exerted by appellant.
The legal logic rests on the principle that in rape cases, the victim’s testimony, if credible, is sufficient to support a conviction. The Court meticulously reviewed the records and found AAA’s account to be natural, convincing, and consistent with human experience. The defense of denial could not prevail over her positive identification. However, pursuant to Republic Act No. 9346, which prohibits the death penalty, the Court modified the sentence from death to reclusion perpetua without eligibility for parole for each count of rape. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the victim.