GR 191390; (April, 2014) (Digest)
G.R. No. 191390 , April 2, 2014
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOEL DIOQUINO Y GARBIN, Accused-Appellant.
FACTS
Accused-appellant Joel Dioquino was charged with eight counts of rape against a 17-year-old minor, ABC. The charges stemmed from incidents occurring from July 31, 1999, to August 16, 1999, in Matnog, Sorsogon. The prosecution evidence, as summarized by the trial court, detailed a series of assaults where the accused repeatedly waylaid the victim, used force and intimidation by boxing her, causing her to lose consciousness, and then had carnal knowledge of her. The incidents occurred in various locations, including near a coconut tree, a nipa plantation, a deserted police detachment, a relative’s house, and a welding shop. The victim did not immediately report the rapes due to threats from the accused that he would kill her and her family if she told anyone. The final incident on August 16, 1999, involved the accused forcibly taking her to another barangay, where a barangay captain (the accused’s uncle) made her sign a handwritten statement claiming she went voluntarily because they were lovers, before she was brought to the police station. The trial court convicted the accused of seven counts of simple rape, acquitting him in one count due to reasonable doubt. The Court of Appeals affirmed the conviction.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for seven counts of simple rape.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. The Court held that the victim’s testimony was credible, straightforward, and consistent, detailing the repeated rapes with clarity. The delay in reporting the crimes was sufficiently explained by the accused’s threats to kill the victim and her family, which instilled fear in her. The Court found no merit in the accused’s defenses of denial and alibi, which were uncorroborated and could not prevail over the positive identification by the victim. The Court sustained the conviction for seven counts of simple rape. The awards of civil indemnity and moral damages were affirmed at ₱50,000 each per count. Additionally, exemplary damages of ₱30,000 were imposed, and an interest of 6% per annum was ordered on all damages from the finality of the decision until fully paid.