GR 171020; (March, 2007) (Digest)
G.R. No. 171020 March 14, 2007
People of the Philippines vs. Alfredo Pangilinan y Trinidad
FACTS
Accused-appellant Alfredo Pangilinan was charged with two counts of rape committed against his daughter, AAA, in September 1995 and January 1997. The prosecution evidence established that the rapes were committed through force and intimidation. AAA testified that her father, while she was sleeping, would remove her clothes, pin her down, cover her mouth to stifle her cries, and forcibly have sexual intercourse with her. She initially kept silent due to threats from her father but eventually confided in her grandmother and mother. A medical examination revealed an old healed hymenal laceration. The defense, consisting solely of appellant’s testimony, denied the accusations, claiming they were fabricated due to marital discord and his wife’s alleged infidelity.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim-witness is paramount in rape cases. AAA’s detailed, candid, and consistent testimony, delivered in a straightforward manner, was found credible and sufficient to establish the elements of rape. The Court noted that her failure to immediately report the incidents was satisfactorily explained by her young age, continuous fear of her father, and his threats against her and her siblings. The medical finding of a healed laceration corroborated her claim of prior sexual abuse. The defense of denial and imputation of ill motive, being inherently weak, could not prevail over the positive and categorical testimony of the victim. The qualifying circumstances of minority and relationship were duly proven, warranting the imposition of the death penalty. However, pursuant to Republic Act No. 9346, the penalty was reduced to reclusion perpetua without eligibility for parole. The Court affirmed the award of civil indemnity, moral damages, and exemplary damages for each count of rape.