G.R. No. 193188 ; August 10, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUANITO APATTAD, Accused-Appellant.

FACTS

Accused-appellant Juanito Apattad was charged with four counts of rape against his daughter, AAA, a minor below 12 years old. The Informations alleged the crimes occurred in 2001 (Criminal Case No. 10172), 2002 (Criminal Case No. 10173), June 10, 2003 (Criminal Case No. 10174), and June 11, 2003 (Criminal Case No. 10175). During pre-trial, the parties stipulated on the identities of the accused and AAA, their father-daughter relationship, AAA’s minority (born October 14, 1994), and the existence of her birth certificate and medico-legal report. AAA testified that the accused raped her in 2001 while she slept with her sisters, and again on June 10 and 11, 2003, by carrying her through a window, covering her mouth, and having sexual intercourse with her. She reported the incidents on June 13, 2003, after which she was examined by Dr. Mila Lingan-Simangan, who found a healed hymenal laceration. The accused denied the charges, claiming his wife initiated the complaint due to marital issues. Defense witness Louie Calimag testified the accused was working and sleeping at his house on June 10 and 11, 2003, and that AAA later recanted, claiming her mother instructed her to lie. The Regional Trial Court convicted the accused of three counts of rape (Criminal Case Nos. 10172, 10174, 10175) and acquitted him in Criminal Case No. 10173, sentencing him to reclusion perpetua for each count and ordering civil indemnity. The Court of Appeals affirmed the conviction with modifications.

ISSUE

The core issue is whether the accused-appellant is guilty beyond reasonable doubt of the crimes of rape.

RULING

The Supreme Court affirmed the conviction. The testimony of AAA, who was a minor at the time of the incidents, was found credible, consistent, and sufficient to establish the elements of rape. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The defense of denial and alibi was rejected for being weak and unsubstantiated, especially in light of AAA’s positive identification. The medical findings of a healed hymenal laceration corroborated AAA’s account. The relationship of father and daughter, and AAA’s minority, qualified the crimes and warranted the imposition of the penalty of reclusion perpetua for each count. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the victim.