GR 200515; (December, 2013) (Digest)
G.R. No. 200515 ; December 11, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LINO PALDO, Accused-Appellant.
FACTS
Accused-appellant Lino Paldo was charged with the qualified rape of his eight-year-old daughter, AAA, alleged to have occurred on the night of March 10, 2001, in Banaue, Ifugao. The prosecution presented AAA, who testified that she was awakened that night by her father, who then removed her pants and inserted his penis into her vagina, causing her pain. She identified him despite the darkness, being familiar with him as her father. Her mother, BBB, testified that AAA reported the incident to her upon her return home on March 12, 2001. The defense presented an alibi, with Paldo and corroborating witnesses claiming he was working in a different barangay, a two-hour hike away, on the alleged date and that AAA was then living with her grandfather elsewhere.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant for the crime of qualified rape beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s clear, candid, and consistent narration of the incident, including how she recognized her father in the dark, was found credible and sufficient to establish the elements of rape. The Court noted that her testimony was corroborated by her prompt disclosure to her mother. The defense of alibi was rightly rejected as inherently weak and unpersuasive, especially against the positive identification by the victim. Alibi cannot prevail over the positive testimony of a credible witness, and it was not physically impossible for Paldo to have been at the crime scene. Furthermore, the qualifying circumstance of relationship (father-daughter) was duly proven through the victim’s birth certificate and stipulations during pre-trial. The penalty of reclusion perpetua without eligibility for parole was correctly imposed. The awards of civil indemnity, moral damages, and exemplary damages were affirmed, with the modification that legal interest shall accrue on the total damages from the finality of judgment until full payment.