G.R. No. 175275 ; February 19, 2008
EMILIO CAMPOS, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Emilio Campos was charged with five counts of qualified rape for allegedly sexually assaulting his 14-year-old daughter, AAA, on five consecutive nights from December 5 to 9, 2001. AAA testified that her father entered her room each night, molested her, and had sexual intercourse with her. She stated she was immobilized by fear due to his cruel and ill-tempered nature, and an attempt to lock her door on December 7 failed as he used a duplicate key. The abuse was interrupted on December 12, 2001, leading to a medical examination. Dr. Brenda Tumacder confirmed a healed laceration in AAA’s vagina consistent with penetration by a blunt object like a penis and noted AAA’s emotional distress.
Campos presented an alibi, claiming he was either playing cards, staying with his mistress Maribel Francisco, or sleeping in a hut during the alleged dates. Maribel and AAA’s younger sister, Marjorie, corroborated his whereabouts. The Regional Trial Court found Campos guilty beyond reasonable doubt of qualified rape and initially imposed the death penalty. The Court of Appeals affirmed the conviction but modified the penalty due to the abolition of the death penalty by Republic Act No. 9346 .

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for five counts of qualified rape.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s clear, candid, and consistent narration of the sequential sexual assaults was found credible and sufficient to establish guilt beyond reasonable doubt. The Court ruled that her failure to shout or physically resist was justified by the moral ascendancy and fear instilled by her father, which constituted intimidation. Her attempt to lock her door demonstrated a desire to resist, and her immediate disclosure to the doctor bolstered her credibility.
The Court rejected the defense of alibi as inherently weak and unsubstantiated. It cannot prevail over the positive identification by the victim, especially given the relationship, which provided opportunity and moral influence. The medical findings, while indicating a healed laceration, corroborated the victim’s account of prior penetration. The qualifying circumstance of the victim being under eighteen and the offender being a parent was duly proven, warranting the penalty of reclusion perpetua without parole for each count. The award of damages was also affirmed.