GR 180914; (November, 2010) (Digest)
G.R. No. 180914 ; November 24, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DOMINGO DOMINGUEZ, JR., alias “SANDY,” Accused-Appellant.
FACTS
Accused-appellant Domingo Dominguez, Jr. was charged with four counts of rape and one count of attempted rape against his 12-year-old daughter, AAA. The prosecution presented AAA, her mother BBB, a relative witness CCC, and a medico-legal officer. AAA testified to multiple incidents of sexual assault by her father inside their home, detailing specific instances in July, August, and September 2001, and an attempted rape in November 2001. The medico-legal report confirmed AAA’s non-virgin state, though no fresh lacerations were found, which was deemed consistent with repeated intercourse. The defense consisted solely of the accused-appellant’s denial, claiming the charges were fabricated due to resentment from his strict disciplinary methods.
The Regional Trial Court convicted the accused-appellant of three counts of rape and two counts of attempted rape. The Court of Appeals affirmed the convictions with modifications to the penalties and damages. The accused-appellant appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in AAA’s testimony and the lack of fresh physical injuries.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for three counts of rape and two counts of attempted rape.
RULING
The Supreme Court denied the appeal and affirmed the convictions. The Court held that AAA’s testimony was credible, straightforward, and consistent on material points. The alleged inconsistencies pertained to minor details and did not undermine the core narrative of sexual abuse. The Court emphasized that testimonies of child-victims are given full weight and credit, as youth and maturity generally make them incapable of fabricating tales of sexual violation. The medico-legal findings, while showing no fresh lacerations, were consistent with repeated sexual intercourse and did not negate the commission of rape.
The defense of denial could not prevail over the positive and categorical testimony of the victim. The Court ruled that the qualifying circumstances of minority and relationship were duly proven by the victim’s certificate of live birth and the marriage contract of her parents. The moral ascendancy of a father substitutes for the requirement of force or intimidation in rape cases. The penalties and awards of damages were affirmed as correctly imposed by the Court of Appeals.