GR 86383; (January, 1990) (Digest)
G.R. No. 86383; January 30, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO ROSELL Y ROGASION, defendant-appellant.
FACTS
The accused-appellant, Reynaldo Rosell, was convicted by the Regional Trial Court of Pasig for the rape of his thirteen-year-old daughter, Rosario Rosell, and sentenced to reclusion perpetua. The complaint alleged that on March 9, 1987, in Pasig, Metro Manila, the appellant, through force, threats, and intimidation, had carnal knowledge of his minor daughter against her will. At trial, the prosecution presented evidence that the victim’s mother discovered Rosario in a distressed state on the morning of March 9. Rosario later confided to an aunt that her father had raped her. Medical examination confirmed recent sexual intercourse, revealing a deep healed laceration on her hymen. Rosario testified that her father had raped her multiple times, including on March 9, and had threatened to kill her and her mother if she resisted or reported the assaults.
The appellant denied the accusation, claiming the complaint was fabricated because he opposed his wife’s plan to work abroad. He argued there was insufficient evidence to prove his guilt beyond reasonable doubt, contending he exercised no moral ascendancy over his daughter.
ISSUE
The sole issue is whether the prosecution evidence is sufficient to prove the appellant’s guilt for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction, modifying the judgment to include an indemnity of Thirty Thousand Pesos (P30,000.00) to the victim. The Court found the prosecution’s evidence, particularly the credible and categorical testimony of the young victim, sufficient to establish guilt. The Court rejected the appellant’s defense as absurd and unworthy of belief, noting that an accusation of this gravity within a family is not lightly made. The Court emphasized the moral ascendancy a father holds over his daughter, which, coupled with threats of death, constituted the intimidation necessary for rape, overcoming any resistance. The medical findings corroborated the fact of recent sexual intercourse. The Court upheld the trial court’s assessment of witness credibility, adhering to the principle that factual findings of the trial court, which observed the witnesses’ deportment, are accorded great weight and respect on appeal. The crime was deemed particularly reprehensible as it was committed by a father against his own daughter.