G.R. No. 220490. March 21, 2018.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALFREDO OPEÑA y BACLAGON, Accused-Appellant.

FACTS

The case stemmed from an Information charging Alfredo Opeña with the rape of his daughter, “AAA,” on May 3, 2007, in Quezon City. The prosecution established that on said date, appellant entered AAA’s room, forcibly removed her clothing and his own, and had carnal knowledge of her despite her resistance and tears, threatening her to keep quiet. AAA revealed that the abuse had been ongoing since she was 11 years old. The following day, she sought help via text message from her aunt, leading to appellant’s arrest. A medico-legal examination confirmed deep, healed hymenal lacerations consistent with penetrating trauma.
Appellant denied the accusation, claiming a good relationship with his daughter and asserting a lack of proof. Both the Regional Trial Court and the Court of Appeals found AAA’s testimony credible, straightforward, and corroborated by medical evidence. The RTC convicted appellant of rape and sentenced him to reclusion perpetua with damages. The CA affirmed the conviction but modified the awarded amounts.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for rape despite alleged failures in the prosecution’s evidence, particularly concerning AAA’s credibility, the delay in reporting, and the absence of proof of force or intimidation.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court systematically addressed appellant’s arguments. First, the delay in reporting the rape, which spanned several years, was deemed not fatal to AAA’s credibility. Jurisprudence holds that such delay is understandable when the perpetrator exercises moral ascendancy and instills fear, as in cases where the rapist is the victim’s father. The Court cited People v. Coloma and People v. Cañada, where similar delays were considered insufficient to discredit the complaint.
Second, the Court ruled that the circumstances of force or intimidation were sufficiently established. Appellant, as AAA’s biological father, possessed moral ascendancy and influence over her, which substitutes for physical violence or overt intimidation. His threat to harm her if she shouted during the incident constituted the requisite intimidation.
Third, AAA’s failure to shout for help was found natural given the context of the threat and the father-daughter relationship, which often engenders fear and submission. The Court emphasized that testimonies of child victims are given full weight and credit. The positive identification by AAA, her credible and consistent narration, and the corroborative medical findings collectively constituted proof beyond reasonable doubt. The awarded damages were sustained in line with prevailing jurisprudence.