G.R. No. 172896 - Seguritan y Jara vs. People

The case is an automatic review of the RTC of Naga City’s decision (Criminal Case No. RTC‑95‑6000) convicting William Alpe y Cuatro of qualified rape, committed against his daughter, Mary Joy Alpe.
The rape occurred in January 1995 in Gainza, Camarines Sur, Philippines, during the early hours of the morning.
The Governed law is Article 335 of the Revised Penal Code as amended by RA 7659, which prescribes the death penalty where the rape of a minor is committed by a parent or relative.

The family—comprising William Alpe, his wife Virginia, and their four children—lived in a one-room affair house, where all members shared limited space and slept on separate mats.
At around 3:00 a.m., Mary Joy was awakened when she felt her father, who was partially dressed (wearing only a T‑shirt and naked from the waist down), near her.
The defendant allegedly removed her clothes, caressed her breasts and private parts, and then forcibly inserted his penis into her vagina following a push and pull movement.
Mary Joy experienced extreme pain, describing it as a feeling of dying, and attempted to extricate herself.
The defendant threatened her silence by warning her not to report the incident, under threat of killing her and other family members.

Virginia recounted waking up to her daughter’s cry, “Mother, my father is beside me.”
She observed her husband engaging in non-consensual sexual acts with their daughter and intervened by pulling him away, leading to further physical abuse where he pushed her and struck her with a piece of wood.

Mary Joy described being awoken, the physical assault by her father, and her subsequent cry for her mother’s help.
She confirmed that the act involved him forcibly having carnal knowledge of her, and that she experienced severe pain during the assault.
Her detailed narration stressed the absence of consent and the repeated nature of the abuse, as she previously suffered similar incidents in May and June 1993.

A physical and internal examination conducted by Dr. Elizabeth Fernandez revealed the presence of a healed hymenal laceration, consistent with the timeline of the assault.
The birth certificate of Mary Joy confirmed her age and identified William Alpe as her father, supporting the charge of incestuous rape.

The appellant denied the rape, arguing that his claim of rape is inconsistent with the physical findings, particularly the presence of only a single hymenal laceration.
He opined that the presence of bolitas in his penis would have caused multiple lacerations if intercourse had occurred, a contention unsupported by evidence or expert testimony.

The abuse was compounded by prior incidents and physical violence, including another criminal case where the defendant mauled his wife.
The rape was statutory rape as Mary Joy was only 14 years old at the time of the assault.
The ongoing threats and pattern of intimidation played a critical role in delaying the reporting of the assault.

The information charged that the crime was committed by a parent against a minor, fulfilling the conditions under which the death penalty is prescribed by RA 7659.
In addition to the criminal conviction, the court ordered the payment of damages—including moral, civil indemnity, and exemplary damages—to compensate for the physical, psychological, and social injury inflicted on the victim.

Whether the trial court erred in finding the appellant guilty of qualified rape beyond reasonable doubt, considering the delay in reporting and the defendant’s contention regarding physical evidence (i.e., the presence of bolitas and a single hymenal laceration).

Whether the testimonies of Virginia Alpe and Mary Joy Alpe were given due weight over the appellant’s conflicting account.
Whether the delay in reporting—attributed to fear and intimidation—undermines the credibility of the victim’s account.

Whether the trial court erred in awarding moral damages of P50,000 to the victim.
The appropriateness of additional awards as civil indemnity ex delicto (P75,000) and exemplary damages (P25,000) in light of the crimes committed.

Whether RA 7659, which prescribes the death penalty in cases where a parent rapes his minor daughter, is constitutionally valid despite dissenting views within the judiciary.