GR 187732; (November, 2012) (Digest)
G.R. No. 187732 . November 28, 2012.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FELIX MORANTE, Accused-Appellant.
FACTS
Accused-appellant Felix Morante was charged with one count of child abuse under Republic Act No. 7610 and six counts of rape against his 12-year-old stepdaughter, AAA. The prosecution alleged that in December 1999, Morante fondled AAA’s breasts and kissed her. Subsequently, from January 10 to 15, 2000, he had carnal knowledge of her nightly, threatening to kill her if she reported the acts. AAA testified that these incidents occurred in their shared home despite the presence of other family members sleeping nearby. Her testimony was corroborated by a medical examination revealing deep, healed lacerations consistent with sexual intercourse.
The defense presented an alibi and denial. Morante claimed the charges were fabricated due to a family dispute over AAA’s earnings. His daughter testified that AAA was working in Bocaue, Bulacan during the alleged rape dates in January 2000. The Regional Trial Court convicted Morante, a decision affirmed with modification by the Court of Appeals, prompting this final appeal.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant for one count of child abuse and six counts of rape.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the credibility of AAA’s testimony, which was straightforward, consistent, and corroborated by medical findings. The defense of alibi and denial cannot prevail over the positive and categorical identification by the victim. The Court found no ill motive for AAA to falsely accuse her stepfather of such grave crimes.
Regarding the alleged inconsistencies in AAA’s testimony about her whereabouts in January 2000, the Court ruled these pertained to minor details that did not undermine the core narrative of the rape. The medical evidence substantiated her claim of sexual abuse. The fact that the crimes were committed in a house with other occupants does not render them impossible, as lust can find opportunities even in seemingly risky conditions. The defense’s claim that AAA was working elsewhere during the specific dates was not sufficiently proven to overturn the trial court’s factual findings, which are accorded high respect. Thus, the prosecution successfully proved Morante’s guilt beyond reasonable doubt for all charges.