G.R. No. L-26241 - People vs. Vicente

The case consolidated three criminal cases (No. 15163-R, 15164-R, and 15368-R) filed against accused-appellant Danilo dela Cruz y Carizza in the Regional Trial Court of Baguio City, Branch 6.
The charges were:

Two counts of rape—one alleging that in September 1990 the accused committed rape against his 11‑year‑old daughter Jeannie Ann dela Cruz, and a second, in July 1995, alleging rape by incest when the victim was 16.
One count of acts of lasciviousness (filed under Republic Act No. 7610) which later was declared void for failing to properly allege the requisite elements of the offense.

Occurred in Baguio City at a residence on Leonard Wood Road when the victim was 11 years old.
Jeannie Ann testified that her father undressed her, forced her to lie down on a cushion, and performed sexual acts that caused her subsequent pain on urination.

Took place in their house when the victim was 16.
Jeannie Ann recounted that, while watching television and in the absence of their mother, the accused forcibly took her into a bedroom where he sexually assaulted her using both manual manipulation and penile insertion.
The testimony highlighted that the accused threatened her with harm to herself, her siblings, and her mother if she resisted or spoke of the incident.

Occurred in the attic of their house on Sumulong Street, Baguio City as Jeannie Ann, this time 18 years old, was returning home from classes.
The victim described a series of sexual acts including fondling, manual insertion, and verbal coercion wherein the accused professed love and attempted to secure her cooperation through threats and promises.
The incident was interrupted by a boarder’s call, yet the accused continued his abusive behavior until the intervention of the police.

Jeannie Ann’s testimony was detailed, consistent, and accompanied by emotional outbursts that underscored her distress and fear.
Medical evidence obtained by Dr. Ronald R. Bandonill supported the occurrence of repeated sexual abuse, noting healed lacerations and lax vaginal walls compatible with multiple episodes of abuse.
Testimonies of other key witnesses, including the victim’s mother (Mrs. Jean dela Cruz) and police officers (SPO2 Melchor Ong and others), corroborated the victim’s narrative and the chain of events.
Documentary evidence regarding the accused’s background, teaching career, and movements between Tarlac and Baguio City provided context to his lifestyle and opportunities for committing the crimes.

The accused-appellant consistently denied the charges, asserting that the victim fabricated her testimony to retaliate for personal grievances, including an alleged breakup with her boyfriend.
He claimed that the delay in reporting the abuse (taking nearly eleven years) and inconsistencies in Jeannie Ann’s account undermined the prosecution’s case.
His defense witnesses testified on his behalf regarding his character as a competent teacher and a devoted family man, although he admitted to unrelated contentious issues such as previous complaints and alleged extramarital associations.

The trial court conducted a joint trial on the consolidated cases where, weighing the evidence, it found the accused guilty on all counts, basing its findings largely on the credible and emotionally compelling testimony of Jeannie Ann.
Specific rulings at trial included:

Imposing reclusion perpetua for the rape committed in September 1990, coupled with an award of moral damages.
Initially sentencing the accused to the death penalty for the July 1995 rape (incest rape), later to be modified on appeal based on insufficient proof regarding the victim’s minority at that time.
Adjudicating an indeterminate sentence for the charge under RA 7610 (acts of lasciviousness), which was ultimately dismissed due to defects in the pleading.

The trial court also ordered the payment of damages, awarding a specific amount for moral damages and later including civil indemnity as required by prevailing jurisprudence.

Whether the victim’s detailed and emotionally charged testimony, despite a significant delay in reporting the incidents, could be accepted as credible beyond reasonable doubt.
How the inherent psychological factors, such as fear and manipulation in incest cases, affect the reliability of a victim’s delayed disclosure.

Whether the nearly eleven‑year delay in reporting the abuse undermines the probative value of the victim’s testimony.
How the delay, when considered in the context of threats and ingrained familial dynamics, should be interpreted by the court.

Whether the prosecution adequately established that the victim was a minor at the time of the alleged rape in July 1995, a requisite for imposing the death penalty under R.A. No. 7659.
Whether the absence of corroborative documentary evidence (birth certificate or equivalent) affected the establishment of this crucial element.

Whether the information charging acts of lasciviousness under RA 7610 sufficiently alleged the elements of the offense as required by the rules of criminal procedure.
If the vagueness and conclusory nature of the allegations violated the accused-appellant’s constitutional right to be informed of the nature and cause of the charges against him.