GR 219963; (June, 2018) (Digest)
G.R. No. 219963 . June 13, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RICARDO TANGLAO Y EGANA, ACCUSED-APPELLANT.
FACTS
Accused-appellant Ricardo Tanglao was charged with the rape of his seven-year-old daughter, AAA. The prosecution’s version established that on September 14, 2001, AAA was sleeping beside her brother DDD in their father’s house. The accused-appellant placed himself between them on a double-deck bed. He covered AAA’s mouth, kissed her, and forcibly inserted his penis into her vagina. DDD, though afraid, witnessed the bed shaking and his sister’s legs quivering. Afterward, AAA whispered to DDD that she had been raped. The following day, AAA reported the incident to her mother, BBB, leading to a medical examination and a barangay report.
The defense presented a different narrative. The accused-appellant claimed AAA went to him to report being abused by her mother’s live-in partner. He alleged he sought help from the DSWD, where AAA initially named another person as her abuser. He insinuated the rape charge was fabricated by BBB due to marital discord. The defense also presented an NBI investigator to challenge the timeline of the medical examination.
ISSUE
Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court found AAA’s testimony, given in a straightforward and categorical manner, to be credible and consistent. The testimony of her brother, DDD, who was present during the incident, provided clear corroboration. The Court emphasized that the testimony of a child-victim of tender years is given full weight and credit, as youth and immaturity generally preclude fabrication. The medical findings, though not conclusive of rape, were consistent with AAA’s account of a penetrating trauma.
The defense of denial and frame-up was rejected for being inherently weak. The accused-appellant failed to prove any ill motive on the part of AAA or her family to falsely accuse him of such a grave crime. The delay in AAA’s medical examination was sufficiently explained and did not undermine her credibility. The totality of the prosecution’s evidence established all the elements of rape under Article 266-A(1)(d) of the Revised Penal Code, committed through force and intimidation and by abusing his moral ascendancy as a father. The Court modified the awarded damages in accordance with prevailing jurisprudence but sustained the penalty of reclusion perpetua.