G.R. No. L-64656 November 18, 1988
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENITO RAMOS, accused-appellant.

FACTS

The accused-appellant, Benito Ramos, was convicted by the trial court of the crime of rape committed against his 16-year-old daughter, Rosemarie Ramos, and was sentenced to reclusion perpetua. The information alleged the rape occurred “during the period comprised between December 22, 1980 and March 30, 1981” through force, intimidation, and threats to kill. The prosecution evidence established that on December 22, 1980, inside their family home, the appellant forcibly removed Rosemarie’s underwear, pulled her hair, and had carnal knowledge of her against her will, threatening to kill her if she resisted. This act was allegedly repeated on multiple subsequent occasions. Rosemarie’s younger sister, Belinda, testified to witnessing a scene where their naked father was on top of a crying Rosemarie while holding a kitchen knife. A medical examination confirmed old hymenal lacerations consistent with frequent sexual intercourse.
The defense interposed denial and alleged improper motive. The appellant claimed the charge was fabricated by his wife and daughter out of resentment following a marital quarrel where he injured his wife, and because he had retrieved Rosemarie from a “tomboy” lover to compel her to resume her studies. He argued the incidents were improbable given the close quarters of their home and denied ever exposing himself to his daughter.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based on the credibility of the prosecution witnesses and the sufficiency of the evidence presented.

RULING

The Supreme Court affirmed the conviction but modified the penalty to include an indemnity award. The Court upheld the trial court’s assessment of witness credibility, finding no reason to deviate from its findings. The rule is settled that the trial court’s evaluation of witness credibility is accorded the highest respect, as it is in the best position to observe demeanor. The appellant’s arguments regarding the delayed reporting of the crime and the alleged improbability of the acts were unavailing. The delay was sufficiently explained by the complainant’s credible testimony that she was threatened with death by her violent-tempered father if she revealed the abuse. The medical findings corroborated the fact of sexual intercourse.
However, the Supreme Court clarified the conviction pertains specifically to the rape committed on December 22, 1980, as initially charged. While the information alleged a period, the subsequent incidents lacked specific dates. The penalty of reclusion perpetua under Article 335 of the Revised Penal Code was correctly imposed. Although the aggravating circumstance of relationship (daughter) attended the crime, it could not increase the penalty as reclusion perpetua is a single, indivisible penalty. The Court thus affirmed the sentence but ordered the appellant to indemnify the victim Rosemarie Ramos in the amount of P30,000.00.