G.R. No. 176498 & 179498, August 3, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. RUSTICO BARTOLINI y AMPIS, Appellant.

FACTS

Appellant Rustico Bartolini was convicted by the Regional Trial Court of three counts of incestuous rape against his two daughters, AAA and BBB. The charges stemmed from separate incidents in March 1994 and March 2, 1998 for BBB, and March 1995 for AAA. The prosecution established that Bartolini, a barangay kagawad, used force, intimidation, and threats to kill family members to coerce his daughters into submission. BBB was raped while weeding a garden and later inside their home. AAA was raped in their garden after being ordered to burn leaves. Both victims reported the assaults to their mother, CCC, who advised silence due to fear of Bartolini’s violent nature. AAA later gave birth to Bartolini’s child in November 1998, which prompted CCC’s relative to report the crimes to authorities.
The defense interposed denial and alibi, claiming the charges were fabricated due to familial discord. The trial court found the testimonies of the victims credible and consistent, convicting Bartolini and imposing the death penalty, which was modified by the Court of Appeals to reclusion perpetua due to the failure to allege the victims’ exact ages in the Informations. Bartolini appealed, arguing the charges were insufficient and the testimonies lacked credibility.

ISSUE

The core issue is whether the Court of Appeals erred in affirming Bartolini’s conviction for three counts of rape despite the alleged defects in the Informations and the credibility challenges raised by the defense.

RULING

The Supreme Court affirmed the conviction. On the sufficiency of the Informations, the Court held that while the exact ages of the victims were not alleged, the charges clearly stated the father-daughter relationship, which is a qualifying circumstance for incestuous rape under Article 335 of the Revised Penal Code, as amended. The Informations adequately informed Bartolini of the nature and cause of the accusations against him, satisfying constitutional and procedural requirements. The failure to specify ages did not vitiate the charges, as the relationship was properly alleged.
Regarding credibility, the Court emphasized that testimonies of rape victims, especially minors, are accorded full credence when consistent and straightforward. The victims’ detailed accounts of force, intimidation, and subsequent threats, corroborated by their mother’s testimony and the birth of AAA’s child, remained unshaken. Delay in reporting was sufficiently explained by the daughters’ fear of their father, a position of moral ascendancy and authority. The defense of denial and alibi, uncorroborated by clear and convincing evidence, cannot prevail over the positive identification and credible narratives of the victims. Thus, the prosecution proved Bartolini’s guilt beyond reasonable doubt for three counts of qualified rape.