GR 186232; (September, 2010) (Digest)
G.R. No. 186232; September 27, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ELPIDIO PAROHINOG ALEJANDRO, Accused-Appellant.
FACTS
The accused-appellant, Elpidio Parohinog Alejandro, was charged with five counts of rape committed against his daughter, AAA, from January 1997 to February 2001. The incidents occurred in their family home in Lebak, Sultan Kudarat, often when AAA was alone. The prosecution’s evidence, primarily AAA’s testimony, detailed how the appellant, through force, intimidation, and threats of family embarrassment, repeatedly sexually assaulted her beginning when she was thirteen years old. AAA did not immediately report the rapes due to fear and shame. The Regional Trial Court convicted the appellant of all five counts of rape, a decision affirmed with modification by the Court of Appeals, which adjusted the awarded damages.
ISSUE
The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for five counts of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s detailed, candid, and consistent narration of the repeated assaults over several years, which bore the hallmarks of truth, was given full weight. The Court found no ill motive for AAA to falsely accuse her own father of such a grave crime. The defense of denial and alibi proffered by the appellant was inherently weak and could not prevail over the positive identification and credible testimony of the victim. The Court also ruled that the failure to immediately report the rapes did not undermine AAA’s credibility, as the delay was sufficiently explained by her young age, continuous fear of the appellant, and his threats causing shame. The emotional and psychological control a father holds over his daughter, creating a morally coercive environment, accounted for the delay and her submission. All elements of rape through force and intimidation were thus established for each count. The Court modified the awards of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.