G.R. No. 183097 ; September 12, 2012
PEOPLE OF THE PHILIPPINES, Appellee, vs. ANTONINO VENTURINA, Appellant.

FACTS

The appellant, Antonino Venturina, was convicted by the Regional Trial Court of Malolos, Bulacan, for two counts of rape committed against his 16-year-old daughter, AAA. The prosecution evidence established that on April 24, 2002, appellant, who was drunk, arrived at the nipa hut where AAA was staying with her sleeping younger brothers. After AAA massaged his chest, appellant suddenly embraced and kissed her, removed their clothes, and had forcible carnal knowledge of her. He then dragged her outside near a chicken pen and again sexually assaulted her, including acts of lasciviousness, threatening her not to tell anyone afterward. AAA reported the incident to her sister, leading to a police complaint and a medico-legal examination which confirmed her non-virgin state.
Appellant denied the accusations, claiming he was working in the fields and later fell unconscious due to chest pains, only to be arrested the next morning. He alleged that AAA fabricated the charges because he had forbidden her from associating with drug users and had grounded her. The trial court found him guilty and initially imposed the death penalty, which the Court of Appeals modified to reclusion perpetua without parole and awarded various damages.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt, particularly challenging the credibility of the victim’s testimony.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court emphasized the settled doctrine that the assessment of witness credibility is best left to the trial court, which had the unique opportunity to observe the witnesses’ demeanor and conduct. In rape cases, the victim’s testimony is of paramount importance, and her lone testimony, if credible, is sufficient to sustain a conviction. The Court found no reason to deviate from the trial court’s findings, as AAA’s detailed and consistent narration of the traumatic events, including the two separate assaults, bore the hallmarks of truth. Her immediate reporting of the incident to her sister and the police bolstered her credibility.
The Court rejected appellant’s defense of denial and frame-up, noting that such allegations are inherently weak and cannot prevail over the positive and categorical testimony of the victim. The medico-legal findings, while not showing fresh injuries, were consistent with AAA’s account, as the absence of external trauma does not negate rape. The Court upheld the penalties imposed by the Court of Appeals, applying Republic Act No. 9346 , which prohibits the death penalty. Thus, the penalty for each count of rape was properly reduced to reclusion perpetua without eligibility for parole. The awards of civil indemnity, moral damages, and exemplary damages were also affirmed as being in accordance with prevailing jurisprudence.