G.R. No. 225793 . August 14, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

The accused-appellant was charged with four counts of qualified rape against his 15-year-old daughter, AAA. The incidents occurred on January 14, 2012 (morning and afternoon), January 18, 2012, and January 21, 2012. In each instance, AAA testified that her father, armed with a bolo, dragged her, removed her clothing, and forced his penis into her vagina despite her resistance and pleas. He threatened to kill her and her mother if she reported the assaults. AAA managed to escape and report the rapes to her aunt and grandmother on January 31, 2012.
A medico-legal examination revealed an intact hymen and no physical injuries. The defense presented denial and alibi, claiming AAA fabricated the charges due to resentment over his relationship with another woman. The Regional Trial Court convicted the accused-appellant of four counts of qualified rape, a decision affirmed with modifications by the Court of Appeals. The accused-appellant appealed to the Supreme Court, arguing the credibility of AAA’s testimony was undermined by the lack of physical evidence and her delayed reporting.

ISSUE

Whether the accused-appellant’s guilt for four counts of qualified rape was proven beyond reasonable doubt despite the medico-legal findings of an intact hymen and the victim’s delayed disclosure.

RULING

Yes. The Supreme Court affirmed the conviction. The Court emphasized that the credibility of a rape victim’s testimony is paramount, especially when the accused is a parent. AAA’s detailed, candid, and consistent narration of the four separate assaults, including the specific dates, times, and use of a bolo for intimidation, was found credible and sufficient to establish guilt. The Court ruled that an intact hymen does not negate rape, as the medico-legal expert, Dr. Rebueno, explained that the acts described by AAA were consistent with “inter labial sex,” where full vaginal penetration does not occur. The delay in reporting was not considered fatal, as it was rationally explained by the accused-appellant’s threats against her and her mother’s life, which instilled fear in a young victim. The defense of denial and alibi, uncorroborated and weak against the positive identification by the victim, was rightly rejected. The qualifying circumstances of minority and relationship were duly proven. The penalty of reclusion perpetua for each count was upheld. Civil indemnity, moral damages, and exemplary damages were set at P100,000.00 each per count, with 6% interest from finality until fully paid.