G.R. No. 178274 March 5, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. AURELIO MATUNHAY, Accused-Appellant.

FACTS

The prosecution charged appellant Aurelio Matunhay, the common-law husband of the victim’s mother (BBB) and the victim’s uncle, with seven counts of rape. The victim, AAA, testified that she was raped seven times by the appellant when she was 14 years old, resulting in a pregnancy and birth in November 1998. She provided detailed accounts of two specific incidents: one in the last week of March 1998, where the appellant threatened her with a bolo, struck her feet with wood, and then had carnal knowledge of her; and another in the first week of May 1998, where he again threatened her with a bolo before raping her. AAA discovered her pregnancy after a medical examination arranged by her teacher and mother, after which she disclosed the appellant was the father and they filed a complaint. BBB corroborated the discovery of the pregnancy and their filing of the complaint. Dr. Amalia Añana confirmed AAA’s pregnancy. The defense consisted of denial and alibi. The appellant claimed he was often at work, staying in a bunkhouse, and suggested AAA had a boyfriend responsible for the pregnancy. His co-worker, Alberto Josol, testified about their work arrangements but admitted they were not always together. The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt of six counts of rape, sentencing him to reclusion perpetua for each count and ordering him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the RTC decision but increased the moral damages.

ISSUE

Whether the Court of Appeals erred in affirming the appellant’s conviction for multiple counts of rape.

RULING

The Supreme Court modified the CA decision. It affirmed the appellant’s conviction but only for two counts of rape (those committed in the last week of March 1998 and the first week of May 1998) and acquitted him of the four other charges. The Court held that AAA’s positive, candid, and straightforward identification and narration of the two specific incidents in March and May 1998 were credible and sufficient to establish guilt beyond reasonable doubt for those counts. The Court deferred to the trial court’s assessment of witness credibility. However, for the other alleged incidents, the Court found the evidence paucity, as AAA could not recall specific dates and her testimony was not sufficiently detailed. The defenses of denial and alibi could not prevail over AAA’s positive identification for the two proven counts. The Court affirmed the penalty of reclusion perpetua for each of the two counts. It sustained the awards of ₱50,000.00 as civil indemnity and ₱50,000.00 as moral damages for each count, and additionally ordered the appellant to pay ₱30,000.00 as exemplary damages for each count.