G.R. No. 192232; December 10, 2014
People of the Philippines, Plaintiff-Appellee, vs. Jose Estalin Prodenciado, Accused-Appellant.

FACTS

The accused-appellant, Jose Estalin Prodenciado, was charged with two counts of Statutory Rape (Criminal Case Nos. 3208-M-2000 and 3209-M-2000) and two counts of Simple Rape (Criminal Case Nos. 3206-M-2000 and 3207-M-2000) committed against his daughter, “AAA”. The Informations alleged that in or about 1993 and 1995, Prodenciado, armed with a bolo, had carnal knowledge of his then 8-year-old and below 12-year-old daughter, respectively. Two more Informations alleged that on August 13, 2000, at about 11:00 a.m. and 11:30 a.m., Prodenciado, again armed with a bolo, raped his 14-year-old daughter. The prosecution’s evidence established that the first rape occurred in 1993 when AAA was 8 years old, inside a hut by the river where Prodenciado threatened her with a knife. The second rape occurred in 1995 when she was 10. On August 13, 2000, Prodenciado raped AAA twice in their hut, dragging her while armed with a bolo, in view of her mother and siblings. The victim’s mother, “BBB”, reported the incidents to the police, leading to Prodenciado’s arrest. A medico-legal examination confirmed AAA was in a non-virgin state. The defense claimed impossibility, alleging AAA lived elsewhere during the incidents and that the charges were fabricated due to anger over his disciplinary actions and his wife’s desire to live with another man. The Regional Trial Court found Prodenciado guilty on all counts, sentencing him to reclusion perpetua for each count and ordering indemnities. The Court of Appeals affirmed the convictions with modifications to the awards of damages.

ISSUE

The core issue is whether the Court of Appeals correctly affirmed the conviction of Jose Estalin Prodenciado for two counts of Statutory Rape and two counts of Simple Rape.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATIONS. The Court upheld the conviction for two counts of Statutory Rape and two counts of Simple Rape. It ruled that the victim’s testimony was credible, consistent, and sufficient to establish guilt beyond reasonable doubt. The Court found that the elements of rape were present: carnal knowledge through force or intimidation, and the victim’s minority (below 12) for the statutory rape charges. The defense of denial and alibi was rejected for being weak and uncorroborated. The Court modified the awarded damages: for each count of Statutory Rape, Prodenciado was ordered to pay AAA P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages. For each count of Simple Rape, he was ordered to pay P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P50,000.00 as exemplary damages. All monetary awards were subject to 6% interest per annum from the finality of the judgment until fully paid. The penalties of reclusion perpetua for each count were affirmed.