G.R. No. 216938 , June 5, 2017
People of the Philippines, Appellee vs. Henry Bentayo, Appellant

FACTS

The appellant, Henry Bentayo, was convicted of incestuous rape against his 15-year-old stepdaughter, AAA. The prosecution established that on September 27, 2006, and again on November 6, 2007, Bentayo, armed with a bolo, forced AAA to accompany him to a farm, threatened her, and succeeded in having carnal knowledge against her will. The second incident, specified in the Information, occurred inside a hut where Bentayo again used force and intimidation. AAA eventually confided in a neighbor, Cordero, after being seen being beaten by the appellant, leading to a police report and a medical examination. The medical findings revealed old, healed lacerations consistent with sexual intercourse.
Bentayo pleaded not guilty, denying the charges and claiming he was alone making charcoal during the alleged incidents. The Regional Trial Court found him guilty beyond reasonable doubt of incestuous rape under Article 266-A in relation to Article 266-B of the Revised Penal Code and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the awarded damages. Bentayo appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming Bentayo’s conviction for incestuous rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The legal logic rests on the established elements of rape and the specific rules governing incestuous rape. Under Article 266-A(1)(a) of the Revised Penal Code, the crime of rape requires: (1) carnal knowledge of a woman, and (2) that it was accomplished through force, threat, or intimidation. However, jurisprudence holds that when the offender is a stepfather of the victim, as in this case, the law presumes moral ascendancy and influence. Consequently, actual force or physical resistance need not be proven; the element of force, threat, or intimidation is subsumed by the stepfather-stepdaughter relationship itself.
The Court found AAA’s testimony credible, straightforward, and consistent. Her detailed account of the two incidents, corroborated by the neighbor’s testimony and the medical certificate showing healed vaginal lacerations, constituted proof beyond reasonable doubt. The defense of denial, unsupported by clear and convincing evidence, could not prevail over the positive identification and credible narrative of the victim. The qualifying circumstance of the victim being under eighteen and the offender being a stepparent warranted the penalty of reclusion perpetua, applied correctly by the lower courts. The award of damages as modified by the Court of Appeals was also sustained.