G.R. No. 181473 ; November 11, 2013
People of the Philippines, Plaintiff-Appellee, vs. Doney Gaduyon y Tapispisan, Accused-Appellant.

FACTS

Accused-appellant Doney Gaduyon was charged with Qualified Rape, Qualified Object Rape, and Sexual Abuse committed against his 12-year-old daughter, AAA. The incidents occurred in their San Mateo, Rizal residence in August and October 2002. On August 21, while AAA’s mother and sisters were away, Gaduyon fondled her breasts and touched her arms. The following night, he had carnal knowledge of her. On October 9, he inserted his finger into her genitalia. AAA’s mother later discovered her in a compromised state. The abuse was eventually reported to school authorities and the police after AAA confided in her teacher and mother.
The Regional Trial Court convicted Gaduyon on all counts, a decision affirmed by the Court of Appeals. On appeal to the Supreme Court, Gaduyon argued that the testimonies of AAA and her mother were inconsistent and incredible. He claimed the charges were fabricated due to family discord and denied the allegations, presenting an alibi that he was working as a security guard during the alleged incidents.

ISSUE

The core issue is whether the prosecution proved Gaduyon’s guilt for the crimes of Qualified Rape, Qualified Object Rape, and Sexual Abuse beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s categorical, consistent, and straightforward narration of the three separate incidents, delivered in a spontaneous and natural manner, was found credible and sufficient to sustain a conviction. Minor inconsistencies in her and her mother’s testimonies regarding peripheral details did not undermine their core credibility but instead indicated unrehearsed truthfulness.
The Court rejected the defense of alibi and denial as inherently weak. Gaduyon failed to prove it was physically impossible for him to be at the crime scene. His moral ascendancy and parental authority as AAA’s father sufficiently established the force and intimidation required for the crimes, rendering physical resistance unnecessary. The qualifying circumstances of minority and relationship were duly proven by AAA’s birth certificate. Consequently, the Court upheld the penalties: death for Qualified Rape (commuted to reclusion perpetua without parole), reclusion perpetua for Qualified Object Rape, and an indeterminate prison term for Sexual Abuse under Republic Act No. 7610 .