GR 212161; (March, 2017) (Digest)
G.R. No. 212161 March 29, 2017
People of the Philippines, Plaintiff-appellee vs. Juanito Entrampas, Accused-Appellant
FACTS
Accused-appellant Juanito Entrampas was the common-law husband of BBB and lived with her and her 11-year-old daughter, AAA, whom he treated as his own. In February 2003, Entrampas, then 50 years old, raped AAA in their home. He threatened to kill her and her mother if she shouted or reported the incident. AAA, out of fear, obeyed and remained silent. The rape was repeated a week later and continued over the following months.
By September 2003, AAA’s physical changes led her mother to suspect pregnancy, which was confirmed by a medical test. Initially, AAA refused to name the father due to fear, but neighbors suspected Entrampas. BBB confronted him, and he allegedly admitted to being the father. Entrampas and BBB then went to BBB’s brother, CCC, where Entrampas confessed and expressed remorse. CCC reported the matter to the police. AAA gave birth in November 2003. Entrampas was charged with two counts of qualified rape.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of Juanito Entrampas for two counts of statutory rape.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s detailed, candid, and consistent narration of the traumatic events, including the threats, the pain, and her subsequent silence due to fear, was found credible and sufficient to establish the crime. Her young age and the moral ascendancy and influence Entrampas held as a father figure made resistance futile and explained her initial silence. The Court noted that the victim’s testimony alone, if credible, is enough to sustain a conviction.
The defense of denial and alibi presented by Entrampas was deemed weak and self-serving, especially when weighed against the positive identification and the corroborative evidence, including the pregnancy and birth of the child. The alleged inconsistencies in AAA’s testimony regarding minor details were considered inconsequential and did not affect the core facts of the rape. The qualifying circumstance that the offender is the common-law spouse of the victim’s mother was duly proven, warranting the imposition of the death penalty. However, due to the prohibition of the death penalty at the time of the commission of the crime, the penalty was properly reduced to reclusion perpetua without eligibility for parole.