G.R. No. 170236 , August 31, 2006
People of the Philippines, Appellee, vs. Roberto Quiachon y Bayona, Appellant.

FACTS

Appellant Roberto Quiachon was charged with the qualified rape of his eight-year-old daughter, Rowena, a deaf-mute. The prosecution presented the testimonies of Rowena, through sign language, and her brother Rowel. Rowel testified that on the night of May 12, 2001, he saw his father on top of Rowena under a blanket, with his buttocks moving up and down, while Rowena was crying. Dr. Miriam Guialani, a medico-legal officer, testified that her physical examination of Rowena revealed a contusion on her cheek, a “kissmark” on her breast, and ano-genital injuries, including hymenal attenuation, consistent with recent chronic penetrating trauma. The defense consisted solely of appellant’s testimony, denying the rape and alleging that the complaint was fabricated by his deceased common-law wife’s relatives who held a grudge against him over property.
The Regional Trial Court convicted appellant of qualified rape and imposed the death penalty. The case was automatically elevated to the Supreme Court but was transferred to the Court of Appeals pursuant to People v. Mateo. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua. The case was then elevated to the Supreme Court for final review.

ISSUE

Whether the Court of Appeals correctly affirmed appellant’s conviction for qualified rape.

RULING

Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings of the trial court and the Court of Appeals, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The testimonies of the child-victim, Rowena, and her brother, Rowel, were found credible, consistent, and corroborated by the medico-legal findings. The Court ruled that the victim’s testimony, even given through sign language due to her being a deaf-mute, was admissible and sufficient to establish the crime. The defense of denial and imputation of ill motive by the relatives was deemed weak and insufficient to overcome the positive and categorical identification by the witnesses. The qualifying circumstance of relationship and the victim’s minority were duly proven, warranting a conviction for qualified rape. However, pursuant to Republic Act No. 9346 , which prohibits the death penalty, the Supreme Court affirmed the modification of the penalty to reclusion perpetua without eligibility for parole. The award of damages was also sustained.