Case Digest (G.R. No. 142728)
Facts:
People of the Philippines charged Doroteo Abano with rape, alleging that on or about August 15, 1996, in Barangay Liminangcong, Taytay, Palawan, he had carnal knowledge of his six-year-old daughter, Judelyn Abano, through force, threat, and intimidation. The Regional Trial Court, Branch 52, Puerto Princesa City convicted Abano on January 18, 2000, imposed the death penalty, and ordered P50,000.00 civil indemnity and P50,000.00 moral damages.
At trial, Judelyn testified in detail and identified Abano as her rapist; Annabelle Fuentes corroborated the incident by hearing Judelyn’s cries and later observing her condition, and Dr. Nestor A. Reyes testified to physical findings consistent with sexual penetration. Abano denied the charge.
Issues:
- Whether the conviction for rape was supported by proof beyond reasonable doubt.
- Whether the qualifying circumstances warranting the death penalty were properly alleged and proven.
- Whether the civil liabilities awarded by the trial court were proper.
Ruling:
The Supreme Court affirmed the conviction and the imposition of the death penalty, finding Judelyn’s testimony credible and corroborated by the medical evidence and Fuentes’s account. It held that the trial court’s credibility findings should not be disturbed absent a showing of overlooked or arbitrary facts.
On civil liability, the Court modified the award of civil indemnity, increasing it from P50,000.00 to P75,000.00, while affirming the P50,000.00 moral damages.
Ratio:
The Court ruled that rape was proven through Judelyn’s categorical and consistent testimony, her positive identification of Abano, and the medical findings of healed hymenal lacerations at 3 o’clock and 9 o’clock, which Dr. Reyes explained could have been caused by a hard object, possibly an adult penis. It also stressed that a young child’s testimony in rape cases deserves full credit, and that Abano’s contentions were not sufficient to overcome the prosecution’s evidence, particularly where the issue centered on credibility.
The Court further found that Abano’s liability was qualified under Section 11 of R.A. No. 7659 because Judelyn was under eighteen and the offender was her parent, both alleged in the Information and proven at trial. It then applied the rule on civil indemnity when the death penalty is imposed, ordering P75,000.00 ex delicto, and maintained the moral damages awarded.
Doctrine:
- The trial court’s assessment of witness credibility, especially in rape cases, is accorded respect and is not disturbed on appeal absent clear showing of arbitrary disregard of significant facts.
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