G.R. No. 213831 , September 25, 2019
The People of the Philippines, Plaintiff-Appellee, v. Adonis Cabales, Accused-Appellant.

FACTS

Accused-appellant Adonis Cabales was charged with the rape of his 13-year-old niece, AAA, on or about January 16, 2005, in Davao, Philippines. The Information alleged he used a knife, force, threats, and intimidation. During trial, AAA testified that while she was sleeping in her house, Cabales, her uncle, woke her by kissing her face, pointed a fan knife at her neck, removed her clothing, and had sexual intercourse with her despite her pleas. She stated this was the second incident, the first occurring in November 2004, which she did not report due to threats. The incident was allegedly witnessed by CCC, who advised her to tell her parents. AAA was medically examined, with findings suggestive of chronic penetrating injury with an acute component. AAA’s mother, BBB, corroborated the timeline, stating she was at Cabales’ house that afternoon and later learned of the rape from CCC. The defense presented alibi and denial, with Cabales claiming he never left his house that day as he was attending to his wife who had just given birth, a claim corroborated by the midwife, EEE. The Regional Trial Court (RTC) convicted Cabales of rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction but reduced the damages. Cabales appealed to the Supreme Court, arguing the prosecution failed to prove guilt beyond reasonable doubt, questioning AAA’s credibility, the lack of resistance, the non-presentation of CCC, and the medical findings.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision finding accused-appellant Adonis Cabales guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court DISMISSED the appeal and AFFIRMED the CA decision with MODIFICATION. The Court held that the prosecution successfully proved Cabales’ guilt beyond reasonable doubt. AAA’s testimony was credible, categorical, and consistent, and the Court emphasized that there is no standard behavioral response for a rape victim; her apparent passivity does not negate rape absent clear evidence of consent. The medical findings, while corroborative, are not indispensable for conviction. The defenses of alibi and denial were inherently weak and could not prevail over AAA’s positive identification. The Court accorded great respect to the factual findings of the trial court, which were affirmed by the CA. The penalty of reclusion perpetua was upheld. The Court modified the damages awarded, increasing civil indemnity and moral damages to PhP 75,000.00 each and awarding exemplary damages of PhP 75,000.00, all with legal interest of 6% per annum from the finality of the decision until full payment.