G.R. No. 219240 APRIL 4, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. BRYAN GANABA y NAM-AY, Accused-Appellant

FACTS

The accused-appellant, Bryan Ganaba, was convicted of rape by the Regional Trial Court (RTC) of Valenzuela City. The prosecution’s case, as narrated by the victim AAA, a 16-year-old nanny in Ganaba’s household, established that on July 1, 2009, Ganaba entered the room where she was feeding his child, locked the door, and used force and intimidation to have carnal knowledge of her. He initially held her arms, and when she resisted, he brandished a knife, threatened to kill her, and proceeded with the sexual assault. AAA immediately reported the incident, leading to Ganaba’s arrest and her medico-legal examination.
In his defense, Ganaba denied the accusation and claimed he was merely watching television at the time. He alleged that AAA fabricated the charge to extort money from him, specifically demanding Two Hundred Thousand Pesos (₱200,000.00) to drop the case. The RTC found AAA’s testimony credible and convicted Ganaba, a ruling affirmed by the Court of Appeals (CA) with modifications to the awarded damages.

ISSUE

The core issue is whether the prosecution proved Ganaba’s guilt for the crime of rape beyond reasonable doubt, particularly in light of his defense of denial and allegation of ill motive for extortion.

RULING

The Supreme Court denied the appeal and affirmed the CA decision. The Court upheld the conviction, ruling that the prosecution successfully established all elements of rape through force and intimidation. AAA’s testimony was found to be clear, convincing, and consistent. She provided a detailed account of the assault, including Ganaba’s use of a knife and threats to kill her, which constituted the intimidation necessary to subdue her will. Her immediate reporting of the crime and the medico-legal findings lent further credence to her testimony.
The Court dismissed Ganaba’s defense of denial and alibi as inherently weak, especially when weighed against the positive identification by the victim. His claim of an extortion attempt was deemed unsubstantiated and insufficient to overturn the factual findings of the lower courts. The Court emphasized that allegations of ill motive, without clear and convincing proof, cannot prevail over the categorical testimony of a rape victim. The penalty of reclusion perpetua was affirmed. The awards of civil indemnity, moral damages, and exemplary damages, as modified by the CA to Fifty Thousand Pesos (₱50,000.00), Fifty Thousand Pesos (₱50,000.00), and Thirty Thousand Pesos (₱30,000.00), respectively, plus legal interest, were sustained.