Case Digest (G.R. No. 128153-56)
Facts:
Vicente Buison y Punsalan was charged and convicted by the trial court of four (4) counts of rape committed against his daughter, Adelina T. Buison. The offenses occurred between 15 August 1991 and 25 October 1991 in General Santos City, with the complainant testifying that her father forcibly raped her on three occasions within about two days and a fourth time on 25 October 1991, while she remained under fear of further harm.
Adelina reported the sexual abuse after escaping to seek help from Fely Bartiana, who brought her to the DSWD. The trial court gave full credence to Adelina’s testimony and rejected alibi and denial; it imposed reclusion perpetua for each count and ordered moral damages of PHP 50,000.00 per count. On appeal, the accused argued the charges were fabricated out of revenge.
Issues:
- Whether the accused’s guilt for the four counts of rape was proved beyond reasonable doubt.
- Whether the award of damages should be modified, particularly the addition of civil indemnity.
Ruling:
The Court affirmed the conviction, holding that the complainant’s testimony remained consistent and credible, and that the accused’s defenses of alibi and denial could not outweigh her direct and categorical accusation. The Court found that alleged inconsistencies were insufficient to discredit her, including her decision to accompany the accused to Davao City as an opportunity for escape and eventual reporting.
The Court modified the damages by ordering, in addition to the moral damages of PHP 50,000.00 per count, the award of PHP 50,000.00 as civil indemnity for each count. It ruled that the offenses occurred before the effectivity of RA 7659.
Ratio:
The Court held that the complainant’s demeanor and detailed narration, corroborated by the medico-legal findings indicating scars possibly caused by a male organ, established the elements of rape beyond reasonable doubt. It also rejected the claim that the complaint was motivated by revenge, noting that upon meeting her father she expressed happiness and showed no hatred or resentment.
The Court further reasoned that seeming departures from “human experience” did not negate credibility because the complainant acted under the accused’s moral ascendancy as her only blood relative in the area and in fear of threats. It likewise gave little weight to defense witnesses who were naturally biased, and sustained the trial court’s credibility assessment.
Doctrine:
- In rape cases, alleged motives of revenge or resentment do not defeat prosecution when the complainant testifies credibly and the elements of the crime are established.
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