Facts:

The case involves Quirino Cabral y Valencia, the accused-appellant, who was charged with five counts of qualified rape against his minor daughter, the complainant, occurring between December 1995 and November 21, 1998. At the time of the incidents, the complainant was aged between 10 and 13 years. The rapes took place in their family dwelling, which measured only three by four meters, during the early hours of the morning when the complainant was asleep with her siblings. The mother of the complainant was absent during these incidents. The accused-appellant used a balisong to threaten the complainant, compelling her to submit to the sexual assaults, and he also threatened to kill her and other family members if she disclosed the acts. The complainant testified that she would awaken to find her father touching her and would cry and kick him during the assaults. The accused-appellant denied the charges, claiming that his work as a tricycle driver and fisherman made it impossibl...

Facts:

1. Background of the Case

• The accused-appellant, Quirino Cabral y Valencia, was charged with five (5) counts of rape committed against his minor daughter (complainant) between December 1995 and November 21, 1998.
• The complainant was 10 to 13 years old during the incidents.

2. Circumstances of the Rape Incidents

• The rapes occurred in the family dwelling, a small house measuring three meters by four meters.
• The incidents happened between 12:00 a.m. and 2:00 a.m. while the complainant was sleeping with her siblings.
• The complainant’s mother was not present during these incidents.
• The accused-appellant used a balisong (knife) to threaten the complainant, poking it at her neck in three instances to compel her submission.
• He also threatened to kill the complainant and other family members if she disclosed the assaults.

3. Complainant’s Testimony

• The complainant testified that she would be awakened by the accused-appellant touching and stroking her thighs.
• He would undress her and himself, then proceed to insert his organ into hers.
• She cried and kicked during the assaults but was unable to shout for help due to fear.

4. Accused-Appellant’s Defense

• The accused-appellant denied the charges, claiming it was impossible for him to commit the rapes due to his nighttime work schedules as a tricycle driver and fisherman.
• He alleged that the complainant and his wife had ill motives: the complainant resented him for disciplining her, and his wife wanted to replace him with another man.

5. Trial Court and Court of Appeals Rulings

• The Regional Trial Court (RTC) acquitted the accused-appellant of one count of rape but convicted him of four counts, imposing the death penalty.
• The Court of Appeals (CA) affirmed the conviction but reduced the penalty to reclusion perpetua for three counts and acquitted him of one count due to insufficient evidence of penile penetration.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of the Complainant’s Testimony

   • The complainant’s testimony was clear, categorical, and consistent. The Court emphasized that no young girl would fabricate charges of such gravity.
   • The trial court’s assessment of witness credibility is accorded great respect unless there is a clear showing of oversight or misappreciation of facts.

2. Physical Evidence

   • The presence of old hymenal lacerations corroborated the complainant’s testimony of sexual assault.

3. Failure to Shout for Help

   • The complainant’s failure to shout was explained by the accused-appellant’s use of a balisong and threats to kill her and her family.

4. Possibility of Rape in a Small Dwelling

   • The Court ruled that rape can occur even in small spaces or in the presence of others. Lust is no respecter of time, place, or relationship.

5. Defenses of Denial and Alibi

   • The accused-appellant’s denial lacked corroboration, and his alibi was directly contradicted by the complainant’s positive identification.

6. Qualifying Circumstances

   • The relationship (father-daughter) and minority of the complainant were proven through her birth certificate and the accused-appellant’s admission in his letters.

7. Penalty and Damages

   • The death penalty was reduced to reclusion perpetua without parole eligibility under Republic Act No. 9346. The damages awarded were adjusted in line with prevailing jurisprudence.