G.R. No. L-62945, September 30, 1983
The People of the Philippines, Plaintiff-Appellee, v. Candido de Castro, Accused-Appellant.

FACTS

The case involves Candido de Castro, accused of raping his daughter, Loyola de Castro, on February 18, 1973, in San Narciso, Quezon. Loyola testified that while she was breastfeeding her infant at home, her father entered, closed the door, and despite her resistance and cries, forcibly had sexual intercourse with her, threatening to kill her if she shouted. After the act, he warned her not to tell anyone. Their neighbor, Braulio Bay (father of Loyola’s common-law husband, Valentin), heard the commotion and threats. Upon entering the house after Candido left, he found Loyola in a disheveled state with a torn dress and a wound; she immediately informed him of the rape.
Loyola wrote to her godmother about the incident four days later and, receiving no response, eventually filed a formal complaint with authorities, leading to the filing of an information for rape. At trial, Candido interposed alibi, claiming he was in another barrio acting as a cockfight judge during the alleged incident, a claim corroborated by his wife and another witness. Defense witnesses also suggested Braulio Bay instigated the charge due to a land dispute with Candido.

ISSUE

Whether the trial court erred in convicting Candido de Castro of rape based on the credibility of the complainant’s testimony, despite the alleged delay in reporting and purported motives for fabrication.

RULING

The Supreme Court affirmed the conviction. The Court meticulously reviewed the records and found no merit in the appellant’s arguments challenging Loyola’s credibility. The alleged delay of 130 days in formally reporting the crime to authorities was sufficiently explained by the circumstances: Loyola first sought help through a letter to her godmother and, when that failed, resorted to writing to President Marcos, which initiated the official investigation. This sequence negates any inference of concoction.
The Court rejected the defense’s theory that the charge was fabricated due to a land dispute or familial discord, deeming such motivations “imaginary.” It emphasized the inherent unlikelihood of a daughter falsely accusing her own father of a grave crime like rape, which would bring shame upon herself and her family, merely to settle an extraneous quarrel. The trial court correctly gave greater weight to Loyola’s consistent and credible narration of the traumatic event over the weak alibi presented by the defense, which was not physically impossible. The presence of the aggravating circumstances of dwelling and relationship was duly considered in the imposition of the penalty of reclusion perpetua and an indemnity.