GR 207990; (June, 2014) (Digest)
G.R. No. 207990 , June 9, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ELIAS BUENVINOTO y PAGLINAWAN, Accused-Appellant.
FACTS
The accused-appellant, Elias Buenvinoto y Paglinawan, was convicted by the Regional Trial Court (RTC) of San Jose, Camarines Sur, Branch 30, for four counts of rape committed against AAA, a 13-year-old girl. The RTC imposed the penalty of reclusion perpetua for each count and awarded civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the RTC decision in toto. AAA was verbally given by her biological father, CCC, to the accused-appellant and his common-law wife when she was an infant, but the adoption was never formalized. AAA testified that she was raped on four separate occasions in 2004 (June 14, July 7, August 18, and September 13), each time through force and intimidation, often at knifepoint. Medical examination revealed AAA’s hymen was intact but distensible, consistent with sexual intercourse. The accused-appellant interposed denial and alibi as defenses, claiming he was elsewhere during the alleged incidents and speculating the complaints were filed to discredit him. The RTC and CA found AAA’s testimony credible and rejected the defenses.
ISSUE
Whether the Court of Appeals erred in affirming the accused-appellant’s conviction for four counts of rape.
RULING
The Supreme Court affirmed the conviction but modified the damages awarded. The Court held that AAA’s credible and categorical testimony, corroborated by medical findings, sufficiently proved the commission of rape. The defense of denial and alibi cannot prevail over positive identification. The Court noted that the special qualifying circumstance of stepfather relationship was not proven, as the accused-appellant was only an adoptive father by verbal arrangement without legal formalities, thus convicting him of simple rape, not qualified rape. The awards were adjusted to conform to prevailing jurisprudence: civil indemnity reduced to ₱50,000.00 per count, moral damages maintained at ₱50,000.00 per count, and exemplary damages increased to ₱30,000.00 per count, all with 6% interest per annum from finality until fully paid.