G.R. No. L-67842 September 24, 1986
People of the Philippines, plaintiff-appellee, vs. Pablo Molero, defendant-appellant.

FACTS

The appellant, Pablo Molero, was convicted by the trial court for the rape of his daughter, Pacita Molero. The prosecution established that on February 5, 1976, Molero brought his then 17-year-old daughter to a secluded riverbank under the pretext of catching fish. There, he forcibly subdued her, brandished a bolo to threaten her, and succeeded in having carnal knowledge against her will. The victim reported the incident days later, and a medical examination revealed old hymenal lacerations consistent with prior sexual intercourse. During a PC investigation, the appellant made an extrajudicial statement, interpreted as an admission of wrongdoing against his daughter’s virtue.
The defense consisted of a denial and an alibi. Appellant claimed he was already in provincial jail since December 1975 and could not have committed the act on the stated date. He also disowned his sworn statement, claiming illiteracy. However, a prison guard testified that jail records showed the appellant was only committed in December 1976, demolishing his alibi for February 1976.

ISSUE

The core issue is whether the guilt of the appellant for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the victim’s testimony and the corroborative evidence, which overwhelmingly outweighed the weak defense. The Court emphasized that the testimony of a rape victim, especially when credible and consistent, is sufficient to sustain a conviction. Pacita Molero’s account was vivid, clear, and remained unshaken despite minor confusion on dates, which the Court found understandable for an illiterate witness. Her testimony was powerfully corroborated by her mother’s actions, the medical findings of old lacerations, and the appellant’s own equivocal admission during investigation.
The appellant’s alibi was thoroughly discredited by official jail records. His denial and claim of illiteracy regarding his sworn statement were deemed unconvincing and self-serving. The Court also noted that the defense, by presenting the complainant as its own witness, inadvertently reinforced the prosecution’s narrative. The moral ascendancy of a father, coupled with the threat of a weapon, constituted the force and intimidation necessary for rape. The Court found no reason to reverse the trial court’s assessment of credibility and thus upheld the finding of guilt beyond reasonable doubt, only modifying the civil indemnity.