G.R. No. L-47200 October 30, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCOS CLARIN, defendant-appellant.

FACTS

The accused, Marcos Clarin, was convicted by the Court of First Instance of Negros Oriental for the rape of his seventeen-year-old daughter, Violenda, and sentenced to death. The prosecution evidence established that on the evening of February 16, 1973, Clarin asked his wife for permission to have Violenda sleep with him in a separate nipa hut, claiming he had nightmares. Violenda, an obedient daughter, consented. Upon reaching the hut, Clarin pointed a knife at her, forcibly removed her panty, and compelled her to lie on the floor. He then had sexual intercourse with her against her will, an act that lasted about an hour. Throughout the night, he lay beside her, hugging her, and suggested repeating the act at dawn, but she pleaded with him as his daughter, and he desisted.
The following day, they returned to their house. The crime was reported, leading to Clarin’s prosecution. The trial court found him guilty, appreciating the aggravating circumstances of abuse of confidence, nighttime, and the victim being his legitimate daughter, and imposed the capital penalty. The case was elevated to the Supreme Court for automatic review.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt based on the complainant’s testimony.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court meticulously examined the complainant’s testimony and found it clear, credible, and consistent. It emphasized the profound lack of motive for a young daughter to fabricate a story of rape against her own father, an accusation that inevitably brings shame and humiliation upon herself and her family. The Court noted that such a charge subjects the victim to a harrowing public ordeal, making it highly improbable that she would willingly undergo this unless driven by truth.
The legal logic applied is the well-settled doctrine that the lone and uncorroborated testimony of the offended party in a rape case is sufficient for conviction, provided it is clear, consistent, and rings with sincerity. The Court found Violenda’s narrative to be impeccable and bearing the stamp of absolute truth and candor. It stood in stark contrast to the accused’s mere denial, for which no plausible motive for the false accusation was shown. The aggravating circumstances were duly considered. However, for lack of the necessary votes to affirm the death penalty, the Court reduced the sentence to reclusion perpetua in accordance with prevailing legal requirements. The judgment was thus affirmed with this modification.