GR 169059; (September 2007) (Digest)
G.R. No. 169059 September 5, 2007
People of the Philippines vs. Lamberto Rafon
FACTS
Appellant Lamberto Rafon was charged with two counts of rape for sexually assaulting his daughter, AAA, in 1994 when she was 11 years old and again in 1998 when she was 15. The prosecution presented AAA’s testimony detailing the incidents, wherein her drunk father used force and threats to have carnal knowledge with her while her mother was working overseas. She did not immediately report the rapes due to fear. Her disclosure to her boyfriend eventually led to a police report in January 1999. A medical examination revealed healed hymenal lacerations consistent with sexual intercourse. The defense consisted solely of appellant’s denial, claiming the case was fabricated by a relative due to a grudge over a debt.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of appellant Lamberto Rafon for two counts of rape qualified by the relationship and the victim’s minority, warranting the penalty of death.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, giving full credence to AAA’s testimony. In rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. AAA’s account was detailed, consistent, and delivered in a straightforward manner. The Court emphasized that it is highly improbable for a daughter to accuse her own father of a grave crime, undergo the ordeal of a public trial, and tarnish the family’s honor unless motivated by a truthful desire for justice. Her initial silence, explained by fear of her father’s threats, is understandable and does not undermine her credibility. The medical findings, while indicating healed lacerations, corroborated her claim of prior sexual intercourse. Appellant’s bare denial cannot prevail over the positive and categorical identification by the victim. The qualifying circumstances of minority and relationship were duly proven by AAA’s birth certificate and her testimony, respectively. However, pursuant to Republic Act No. 9346, the penalty is reduced to reclusion perpetua without eligibility for parole for each count. The awards of civil indemnity, moral damages, and exemplary damages are affirmed.