GR 171164; (November, 2008) (Digest)
G.R. No. 171164 November 28, 2008
People of the Philippines, plaintiff-appellee vs. Nasario Castel, accused-appellant.
FACTS
Accused-appellant Nasario Castel was indicted for seven counts of rape committed against his sixteen-year-old daughter, AAA. The charges specified incidents occurring in February, April, June, August, September, November, and on December 20, 1997, in Malolos, Bulacan. During trial, AAA testified to a series of rapes beginning on December 19, 1996, where her father, after escorting her mother to work, would return, mount her, undress her, and have carnal knowledge against her will through force and threats. The rapes occurred in her parents’ bedroom at dawn, with appellant threatening to kill her and slapping her when she cried. AAA did not immediately report the incidents due to fear. She eventually disclosed the abuse to her aunt in February 1998, leading to a medical examination which revealed multiple healed hymenal lacerations. The prosecution presented testimonies from AAA, the medico-legal officer, her aunt, grandmother, a police officer, and a doctor from the National Center for Mental Health. The defense presented appellant and his wife, who denied the accusations.
ISSUE
The primary issue is whether the prosecution proved beyond reasonable doubt the guilt of Nasario Castel for the crimes of rape.
RULING
The Supreme Court affirmed the conviction of Nasario Castel for six counts of rape but acquitted him for one count (Criminal Case No. 1547-M-98 for the alleged rape on December 20, 1997) due to insufficient evidence, as the prosecution failed to elicit details of that specific incident from AAA. The Court found AAA’s testimony credible, straightforward, and consistent, detailing the repeated sexual assaults by her father. The medico-legal findings of healed hymenal lacerations corroborated her claim of prior sexual intercourse. The defense of denial and alibi was deemed weak and unsubstantiated. The Court modified the penalty imposed by the lower courts. Applying Republic Act No. 9346 , which prohibits the death penalty, the Court sentenced appellant to reclusion perpetua for each count of rape, without eligibility for parole, and ordered him to pay civil indemnity, moral damages, and exemplary damages to the victim.