G.R. No. L-42962. April 30, 1984.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO EGOT, defendant-appellant.

FACTS

The appellant, Pedro Egot, was convicted of rape and sentenced to reclusion perpetua by the lower court. The victim was his 11-year-old stepdaughter, Ligaya de la Cruz. She testified that on the night of December 23, 1971, while her mother was convalescing in Dumaguete City, she was awakened by the appellant on top of her. He overpowered her, threatened to choke her if she shouted, and consummated the sexual act. He threatened to kill her if she revealed the incident. She also alleged a second rape on December 27, 1971. The crime was revealed in April 1972 when the victim’s mother became suspicious. A medical examination on May 15, 1972, by Dr. Filipinas Nielo revealed old hymenal lacerations consistent with sexual intercourse around five months prior, corroborating the December 1971 allegation.
The defense, through appellant’s brief, contended that the constitutional presumption of innocence was not overcome. Counsel argued the appellant was a good family man and provider, and highlighted the five-month delay in filing the complaint as undermining the prosecution’s case. The defense suggested the charge was fabricated.

ISSUE

Whether the constitutional presumption of innocence of the accused was successfully overcome by proof of guilt beyond reasonable doubt.

RULING

Yes, the presumption of innocence was overcome. The Supreme Court affirmed the conviction, with modification only as to the indemnity. The Court meticulously applied the standard that accusation is not synonymous with guilt, requiring moral certainty from the evidence. The defense’s arguments were found insufficient to create reasonable doubt. The claim that the appellant was a “good family man” is a non sequitur and does not preclude the commission of the crime. The delay in reporting was credibly explained by the victim’s fear due to the appellant’s death threats, a common reaction in rape cases, especially when the offender is a person in authority like a stepfather.
The Court found the victim’s testimony credible and consistent. Her young age and relationship to the appellant made it highly improbable she would fabricate such a grave charge. The medical evidence provided strong corroboration, as the old lacerations were consistent with the timeline of the alleged rape in December 1971. The Court also noted the weakness of the defense, which failed to present witnesses, like Romy Ranila or neighbor Marievic Cuevas, who could have substantiated the appellant’s alibi. However, the Court, aligning with the Solicitor General’s observation, found the evidence for the alleged second rape on December 27, 1971, less convincing, as the victim’s mother was reportedly home by then. This did not, however, weaken the case for the first, well-corroborated rape. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P12,000.00.