GR 228248; (August, 2017) (Digest)
G.R. No. 228248 . August 9, 2017
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ROMEO DE GUZMAN Y DE CASTRO, ACCUSED-APPELLANT.
FACTS
Two Informations charged accused-appellant Romeo De Guzman with Qualified Rape under Article 266-A, in relation to Article 266-B, of the Revised Penal Code. Criminal Case No. 11-0539 alleged he raped his eight-year-old stepdaughter, AAA, in 2003. Criminal Case No. 11-0541 alleged repeated rapes between 2006 and 2010, when AAA was between eleven and fifteen years old. The prosecution presented AAA, who testified that De Guzman first raped her in 2003 in their Las Piñas home, warned her to stay silent, and continued the abuse until 2010. Her testimony was corroborated by her aunt, CCC, to whom she eventually confided. A medico-legal report confirmed hymenal lacerations consistent with sexual intercourse.
De Guzman denied the accusations, interposing alibi and denial. He claimed he was in Pangasinan during the alleged 2003 incident and was never alone with AAA. He further imputed ill motive and bad behavior on AAA’s part. His defense was supported by the testimony of BBB, AAA’s mother, who believed the rape charges were false. The Regional Trial Court found De Guzman guilty beyond reasonable doubt of two counts of Qualified Rape, a decision affirmed with modifications by the Court of Appeals. De Guzman appealed to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant for two counts of Qualified Rape.
RULING
The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that the prosecution successfully proved De Guzman’s guilt beyond reasonable doubt. AAA’s testimony was clear, categorical, and consistent, detailing the rapes with vivid recollection. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount, especially when the victim is a minor. AAA’s straightforward narration, absent any evidence of improper motive to falsely accuse her stepfather, was deemed credible and sufficient to sustain a conviction.
The Court rejected De Guzman’s defenses of alibi and denial as inherently weak. Alibi cannot prevail over the positive identification by the victim, and denial is an unsubstantiated defense that merits no weight against affirmative testimony. The qualifying circumstance of the offender being a step-parent of a victim under eighteen years of age was duly proven, warranting the penalty for Qualified Rape. However, as the death penalty is prohibited, the proper penalty is reclusion perpetua without eligibility for parole. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the victim, in accordance with prevailing jurisprudence.