G.R. No. 203322 February 24, 2016
PEOPLE OF THE PHILIPPINES, Appellee, vs. REMAN SARIEGO, Appellant.

FACTS

Appellant Reman Sariego was charged with two counts of rape against his 17-year-old daughter, AAA. The prosecution alleged that on December 15, 2000, and February 20, 2001, in Cebu City, appellant, through force and intimidation, had carnal knowledge of AAA against her will. AAA testified that on both occasions, her father compelled her to submit to sexual intercourse, threatening to kill her and their family if she reported the acts. She revealed the assaults only after becoming pregnant, subsequently giving birth and leaving the child in a home for unwed mothers. Medical examination confirmed previous hymenal lacerations and her pregnancy.
The defense consisted solely of appellant’s testimony, denying the charges and alleging that AAA’s boyfriend impregnated her. He admitted to having physically disciplined AAA in the past for flirting but denied any sexual abuse. The Regional Trial Court convicted appellant of two counts of rape, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for two counts of rape based on the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the victim’s testimony was credible, straightforward, and consistent. In rape cases, the credibility of the complainant is paramount, and AAA’s detailed account of the incidents, including the use of force and intimidation stemming from appellant’s moral ascendancy as her father, was deemed sufficient to establish guilt beyond reasonable doubt. The medical findings corroborated her claim of sexual intercourse.
The Court rejected appellant’s bare denial and his alternative explanation for the pregnancy. Denial, being inherently weak, cannot prevail over the positive and categorical testimony of the victim, especially when no ill motive was shown for her to falsely accuse her own father. The element of force or intimidation was sufficiently established through appellant’s threats and his admitted past acts of violence, which instilled fear in AAA. The delay in reporting the crime was justified by her fear and the continuing threats, and does not undermine her credibility. The penalties and awards of civil liability and moral damages were sustained.