G.R. No. 189293; July 10, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VICENTE CANDELLADA, Accused-Appellant.

FACTS

Accused-appellant Vicente Candellada was charged with one count of attempted rape (Criminal Case No. 118-07-2005) and eight counts of consummated rape (Criminal Case Nos. 159-07-2005 to 166-07-2005) committed on specified dates from May 30 to December 25, 2004, against his daughter, AAA, who was 14 years old at the time of the incidents. During pre-trial, the defense admitted that accused-appellant is AAA’s father and that AAA was 15 years old at the time of the commission of the crimes and/or filing of the cases.
The prosecution’s evidence established that AAA, born on January 10, 1990, was impregnated by her father while they were still in Davao. When she was five months pregnant, accused-appellant brought her to Lanao del Norte on May 30, 2004. They stayed in the old house of Elsie Gemina, to whom accused-appellant introduced AAA as his wife. While living there, accused-appellant had sexual intercourse with AAA on the eight dates specified in the Informations. AAA consistently resisted but was threatened with a knife. She gave birth to a baby boy on September 24, 2004, who died four days later. On December 28, 2004, accused-appellant made amorous advances which AAA refused, leading him to maul her and hit her head with a piece of wood, rendering her unconscious. Gemina sought help, resulting in accused-appellant’s arrest. A medical examination of AAA on December 29, 2004, revealed hematoma, contusions, and abrasions. During the investigation of the mauling, AAA revealed the rapes.
The defense consisted solely of accused-appellant’s testimony. He denied raping AAA, claimed he introduced her as his daughter, and stated her pregnancy was by a classmate. He also asserted he was already in jail on December 23, 2004, and could not have attempted rape on December 28.
The Regional Trial Court (RTC) acquitted accused-appellant of attempted rape for lack of evidence but found him guilty of eight counts of rape, crediting AAA’s testimony as “convincing and straightforward.” The Court of Appeals affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for eight counts of rape.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals. The Court held that the prosecution successfully proved accused-appellant’s guilt for eight counts of rape beyond reasonable doubt.
The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s testimony was found to be credible, straightforward, and consistent. The Court noted that her detailed account of the rapes, including the specific dates and the use of threats, remained unshaken during cross-examination. The fact that she did not immediately report the rapes was not considered fatal to her credibility, given her young age, the threats from her father, and the absence of a trusted guardian. The defense of denial by accused-appellant, unsupported by evidence, could not prevail over AAA’s positive identification and testimony. The relationship of father and daughter, which was admitted, further bolstered AAA’s credibility, as it was highly improbable for a daughter to falsely accuse her father of a crime that would bring shame to the family. The medical findings, while not conclusive of rape, were consistent with AAA’s account of physical abuse. The Court found no reason to deviate from the factual findings of the trial court, which were affirmed by the Court of Appeals, as there was no showing that any fact or circumstance of weight was overlooked. Accordingly, the conviction was upheld.