GR 177572; (February, 2008) (Digest)
G.R. No. 177572 ; February 26, 2008
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUANITO DELA CRUZ Y RIVERA, accused-appellant.
FACTS
The accused-appellant, Juanito dela Cruz, was charged with four counts of rape committed against his daughter, AAA. The informations alleged that the rapes occurred in March 1995, repeatedly during 1996 and 1997, and on July 24, 1998, all within their family residence. AAA testified that her father, taking advantage of the absence of her mother, would sexually assault her through force, intimidation, and physical violence, including punching and slapping. He threatened to kill her and other family members if she reported the incidents. The abuse was eventually reported to the National Bureau of Investigation after AAA’s aunt was informed. A medico-legal examination revealed an intact but distensible hymen, consistent with penetration. The defense consisted solely of appellant’s denial, claiming the charges were fabricated due to familial discord.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s detailed, candid, and consistent narration of the repeated sexual assaults, including the specific circumstances of force and threats, was found credible and sufficient to establish guilt. The Court ruled that her failure to immediately report the rapes did not undermine her credibility, as the delay was satisfactorily explained by her genuine fear of appellant, who was her father and wielded moral ascendancy and physical dominance over her. The medico-legal findings, while showing an intact hymen, were deemed not fatal to the prosecution’s case, as an intact hymen does not preclude rape, and the medical report indicated the orifice was wide enough to allow penetration without injury, which was consistent with AAA’s testimony.
The defense of denial, being inherently weak, could not prevail over the positive and credible testimony of the victim. The Court found that all elements of rape were present: carnal knowledge through force or intimidation, with the aggravating circumstance of relationship (father-daughter) duly alleged and proven. The Court modified the awards of damages in accordance with prevailing jurisprudence but upheld the penalty of reclusion perpetua for each count of rape. The decision underscores the principle that in incestuous rape, the victim’s testimony, if credible, is sufficient to sustain a conviction.