G.R. No. 188561 ; January 15, 2010
People of the Philippines, Appellee, vs. Felipe Ayade y Pulod, Appellant.

FACTS

Appellant Felipe Ayade y Pulod was charged with Qualified Rape for allegedly having carnal knowledge of his daughter, VVV, a girl under thirteen years old, on March 26, 2003, in Mandaluyong City. Upon arraignment, he pleaded not guilty. The prosecution presented VVV’s testimony that at around 12 noon on said date, while she was alone in their house and her mother was at work, her father entered her room, touched her breasts, undressed her, kissed and licked her breasts and vagina, mounted her, forced his penis into her vagina, and had sexual intercourse with her. She resisted and cried, but Ayade punched her thigh to prevent her from shouting. After the incident, VVV reported the assault to her grandmother, GGG, and they reported it to the police. Ayade denied the accusation, claiming he was at work during the alleged incident and that the case was fabricated by GGG due to a dispute over an electric bill payment. The Regional Trial Court (RTC) convicted Ayade of Qualified Rape, sentencing him to Reclusion Perpetua without parole and ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the conviction but modified the amounts of moral and exemplary damages. Ayade appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of appellant Felipe Ayade y Pulod for the crime of Qualified Rape.

RULING

The Supreme Court denied the appeal and affirmed the CA Decision with modification. The Court held that the appeal was bereft of merit. It reiterated that in rape cases, conviction can rest solely on the credible testimony of the victim, which must be scrutinized with extreme caution. The Court found that Ayade only proffered the defenses of denial and alibi, which are weak and cannot prevail over the positive and unequivocal identification by the victim, VVV. No ill motive was shown for VVV to falsely accuse her own father; the alleged motive of the grandmother was deemed illogical and absurd. The trial court’s findings on the credibility of witnesses were accorded high respect, as affirmed by the CA, and no cogent reason was found to deviate from these findings. However, the Court modified the CA’s award by reinstating the RTC’s award of moral damages in the amount of ₱75,000.00, in line with current jurisprudence. Thus, the appellant was found guilty beyond reasonable doubt of Qualified Rape and ordered to pay civil indemnity of ₱75,000.00, moral damages of ₱75,000.00, and exemplary damages of ₱25,000.00.