GR 176153; (September 2007) (Digest)
G.R. No. 176153; September 21, 2007
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. OLIGARIO BALONZO, Accused-Appellant.
FACTS
The accused-appellant, Oligario Balonzo, was charged with the qualified rape of his then 15-year-old daughter, AAA. The Information alleged that on the evening of 14 July 2002, inside their dwelling, Balonzo, with force, threat, and intimidation, had carnal knowledge of AAA against her will. AAA testified that on that night, and also on a prior occasion in June 2002, her father entered the room where she slept, threatened to kill her siblings if she told anyone, and proceeded to rape her. She did not resist due to fear, a sentiment compounded by previous instances where her intoxicated father had chased her with a bolo. She later disclosed the rape to her brother, BBB, who helped her file a complaint. The defense consisted solely of Balonzo’s denial, claiming a previously harmonious relationship and suggesting the accusation stemmed from a grudge after he forbade AAA from going out.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for qualified rape.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the findings of the trial and appellate courts, giving great weight to the credibility of AAA’s testimony. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. AAA provided a clear, consistent, and candid account of the two incidents, which was corroborated by her prompt reporting to her brother and the authorities. Her failure to physically resist was justified by the moral ascendancy and intimidation wielded by her father, compounded by his explicit death threats against her siblings. The defense of bare denial cannot prevail over the positive and credible identification by the victim. The Court found the qualifying circumstances of minority and relationship were duly proven, warranting a conviction for qualified rape. However, pursuant to Republic Act No. 9346, the penalty was reduced from death to reclusion perpetua. The awarded damages were also modified, increasing moral damages to Seventy-Five Thousand Pesos (Php75,000.00) in line with prevailing jurisprudence.