GR 175836; (January, 2009) (Digest)
G.R. No. 175836 January 30, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. RUBEN CORPUZ y SIMON, Appellant.
FACTS
Appellant Ruben Corpuz was charged with six counts of rape against his alleged stepdaughter, AAA, in six separate Informations alleging that from April to September 2002, he had carnal knowledge of AAA, a woman under eighteen, by means of force and intimidation, with the crime aggravated by him being the stepfather of the victim. During trial, AAA testified that appellant, the live-in partner of her mother BBB, would, while armed with a gun and a knife, pull her into a room, threaten to kill her and her mother if she did not submit, and then have sexual intercourse with her. She disclosed the rapes in October 2002 due to pregnancy concerns, later giving birth to a child. Appellant admitted to having sexual intercourse with AAA several times during the stated period but claimed it was consensual, invoking a “sweetheart” defense, and acknowledged paternity of the child. The Regional Trial Court found him guilty of six counts of qualified rape and imposed the death penalty for each. The Court of Appeals affirmed the conviction but modified the characterization to simple rape, sentencing him to reclusion perpetua for each count and adjusting the damages.
ISSUE
Whether the Court of Appeals correctly affirmed appellant’s conviction for six counts of simple rape and the corresponding penalties and damages.
RULING
Yes, the Supreme Court affirmed the Court of Appeals’ Decision with modification regarding civil indemnity. The Court upheld the credibility of AAA’s testimony, noting the trial court’s superior position to assess witness demeanor and finding no reason to disturb its findings. It rejected appellant’s “sweetheart” defense for lack of corroborating evidence. The Court ruled that moral ascendancy, given appellant’s position as the common-law spouse of AAA’s mother, substituted for force or intimidation. However, it agreed with the appellate court that the crime was simple rape, not qualified, because while AAA’s minority was alleged and proven, the Informations inaccurately alleged a stepfather-stepdaughter relationship instead of the proven live-in partner relationship, which must be specifically alleged to qualify the offense. The Court modified the damages, awarding ₱50,000 as civil indemnity, ₱50,000 as moral damages, and ₱25,000 as exemplary damages for each count of simple rape.