GR 234240; (February, 2019) (Digest)
G.R. No. 234240 February 6, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. NOEL NAVASERO, SR. y HUGO, Accused-Appellant
FACTS
Accused-appellant Noel Navasero, Sr. was charged with fifteen counts of qualified rape committed against his biological daughter, AAA, from 2010 to 2013, beginning when she was ten years old. AAA testified in detail about each incident, explaining how she specifically remembered the dates. She stated that after the last rape in September 2013, she informed her mother, leading to the filing of the cases. Navasero denied the accusations, claiming they were fabricated by AAA as retaliation for the physical discipline he imposed.
The Regional Trial Court found Navasero guilty on all counts and sentenced him to reclusion perpetua for each count without eligibility for parole, also awarding moral damages. The Court of Appeals affirmed the conviction but modified the damages, increasing the moral damages and awarding civil indemnity and exemplary damages for each count.
ISSUE
Whether the Court of Appeals erred in affirming Navasero’s conviction for fifteen counts of qualified rape.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court held that AAA’s testimony was credible, categorical, and consistent. The defense of bare denial could not prevail over her positive identification. The Court emphasized that the trial court’s assessment of witness credibility is entitled to great weight, as it had the direct opportunity to observe the witness’s demeanor.
The legal logic rests on the elements of qualified rape under Article 266-A of the Revised Penal Code, as amended. The prosecution successfully proved that carnal knowledge occurred through force and intimidation, and that the qualifying circumstance of the victim being a minor and the offender being her parent was present. The Court found AAA’s detailed narration, including her explanation for remembering specific dates, to be natural and indicative of truth. The repetitive nature of the acts, which the appellant argued made the testimony incredible, is tragically common in incestuous rape cases and does not detract from credibility. The award of damages was sustained as proper under prevailing jurisprudence, with the imposition of interest on all monetary awards from finality until full payment.