G.R. No. 186234; December 21, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. FELIX PALGAN, Appellant.

FACTS

The appellant, Felix Palgan, was convicted by the Regional Trial Court for two counts of rape against his stepdaughter, AAA. The first incident occurred on March 16, 1997, in a rubber plantation, where appellant confronted AAA about rumors that he was not her father, then forcibly had carnal knowledge of her. The second incident transpired on September 9, 1997, inside their home while AAA’s mother was away; appellant again sexually assaulted her. AAA initially remained silent due to threats but eventually disclosed the rapes after her mother discovered a suggestive letter. A medical examination revealed vaginal laxity consistent with repeated manipulation or penetration. Appellant denied the accusations, presenting alibis and claiming the charges were fabricated due to a family dispute over land.

ISSUE

Whether the prosecution proved the guilt of the appellant for two counts of rape beyond reasonable doubt.

RULING

Yes, 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 two incidents, which remained unshaken during cross-examination, was found credible and sufficient to establish the elements of rape through force and intimidation. The trial court’s assessment of witness credibility is accorded great respect, and no substantial reason was shown to overturn it. The medical findings, while not conclusive of recent penetration, corroborated AAA’s account of repeated sexual abuse. Appellant’s defenses of denial and alibi, inherently weak and unsupported by clear evidence, could not prevail over the positive identification and credible testimony of the victim. The awards for civil indemnity were proper, but moral damages were increased to ₱50,000.00 per count, in line with prevailing jurisprudence.