GR 195239; (March, 2012) (Digest)
G.R. No. 195239 ; March 7, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BEN RUBIO y ACOSTA, Accused-Appellant.
FACTS
Accused-appellant Ben Rubio y Acosta was charged with the qualified rape of his 15-year-old daughter, AAA, on January 8, 2000, in Pasig City. During trial, AAA testified that while she was sleeping with her younger siblings, Rubio approached her, removed her clothing, and succeeded in having carnal knowledge of her despite her resistance. She immediately reported the incident to a barangay tanod, leading to the filing of a complaint. The medico-legal examination revealed healed lacerations consistent with prior sexual assaults. AAA also recounted a prior rape in 1993, which her mother dismissed. For his defense, Rubio denied the accusation, arguing that the small, multi-family dwelling where the alleged rape occurred made such an act impossible without detection, and suggested AAA fabricated the story due to a grudge over his womanizing.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for qualified rape beyond reasonable doubt, hinging on the credibility of the victim’s testimony.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the complainant is paramount, and the trial court’s assessment thereof is accorded great respect, absent any showing of arbitrariness. The RTC and CA found AAA’s testimony to be clear, consistent, and credible. Her immediate reporting of the crime to authorities corroborated her account and demonstrated her natural reaction. The medico-legal findings, while indicating healed injuries, did not negate the commission of rape, as the absence of fresh injuries is not fatal to the prosecution’s case, especially given AAA’s detailed narration of force and intimidation.
The Court rejected the defense of alibi and impossibility, noting that lust is no respecter of time or place, and rape can be committed even in crowded surroundings when the aggressor is determined. The claim of ill motive was deemed insufficient to overturn the positive and categorical identification by the victim. The relationship of father and daughter, which Rubio admitted, qualified the crime and warranted the imposition of reclusion perpetua without parole. The award of damages was sustained. The conviction was thus upheld, as the prosecution’s evidence met the required quantum of proof beyond reasonable doubt.