G.R. No. 202187 February 10, 2016
People of the Philippines, Appellee, vs. Eliseo D. Villamor, Appellant.

FACTS

Appellant Eliseo D. Villamor was charged with five counts of rape committed against his 15-year-old daughter, AAA. The prosecution alleged that on five separate dates in November and December 2005, appellant, while AAA was asleep beside her siblings and grandmother, would awaken her by fondling her, threaten to kill her if she made noise, and then forcibly have carnal knowledge with her. AAA, fearing for her life and having no immediate recourse as her mother was working abroad, initially did not report the incidents. She only disclosed the rapes in April 2006 after discovering she was pregnant. Her testimony was corroborated by medical findings confirming her pregnancy timeline and a Child Study Report detailing her trauma.
The defense presented only appellant’s testimony, interposing denial and alibi. He claimed it was physically impossible to commit the rapes as he slept in a separate hut during the alleged period. He further alleged that AAA’s pregnancy was caused by her boyfriend, with whom she had supposedly married in April 2006. The Regional Trial Court convicted appellant of five counts of rape, a decision affirmed by the Court of Appeals.

ISSUE

Whether the guilt of appellant for five counts of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s clear, candid, and consistent narration of the harrowing incidents, including specific details of how her father threatened and assaulted her, was found credible and sufficient to establish guilt. The defense of denial and alibi, inherently weak and uncorroborated, cannot prevail over the positive identification and credible testimony of the victim. The Court noted that AAA’s initial silence, out of fear and the moral ascendancy of her father, is understandable and does not undermine her credibility. The alleged marriage to a boyfriend was deemed a mere fabrication, unsupported by any evidence and contrary to the logical sequence of events, including the immediate filing of the complaint upon her mother’s return. The medical evidence corroborated the timeframe of the sexual assaults. Consequently, the Court upheld the penalty of reclusion perpetua for each count of rape, with the corresponding civil liabilities. The appeal was denied for lack of merit.