GR 91158; (May, 1992) (Digest)
G.R. No. 91158 May 8, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIPE SANGIL y VELISARIO, respondent.
FACTS
The accused-appellant, Felipe Sangil, was convicted by the Regional Trial Court of Malolos, Bulacan, for the crime of rape committed against his daughter, Joselyn Sangil. The prosecution evidence established that in September 1983, when Joselyn was 13 years old, her father awakened her at midnight, removed her panty, threatened to kill her if she did not submit, and succeeded in having carnal knowledge with her. She did not shout for help due to fear. He raped her again in November 1984 under the same threat. The crimes came to light in January 1989 after Joselyn’s sister, Alicia, became pregnant and confessed that their father was the author. During a family confrontation, sisters Araceli and Lourdes also confessed to having been raped by the accused. Dr. Fe Mesina, who medically examined the four Sangil sisters, confirmed that their hymens were totally lacerated, consistent with sexual intercourse, and that Alicia was pregnant. The accused denied the allegations, attributing the complaint to his cruelty towards his children and a family dispute over property. He admitted writing letters asking for forgiveness for maltreating them but denied fathering Alicia’s child.
ISSUE
Whether the trial court erred in convicting the accused-appellant of rape based on the evidence presented.
RULING
The Supreme Court affirmed the conviction with modification. It upheld the trial court’s findings, giving highest respect to its assessment of witness credibility. The Court found no reason to disbelieve the complainant’s testimony, noting that a young woman of decent repute would not publicly admit rape and undergo the ordeal of a trial unless it were true, especially against her own father. The delay in reporting was justified by the accused’s threats and the complainant’s young age at the time of the assaults. The Court clarified that the proper penalty for rape is reclusion perpetua, not life imprisonment, as they carry different accessory penalties. The decision was affirmed with the modification that the penalty is reclusion perpetua with its accessory penalties. The appellant was also ordered to pay increased damages of P40,000 to the offended party due to the heinous nature of the crime.