Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Felipe de los Santos y Cachuelo, the accused-appellant. The events transpired on September 12, 1994, in Quezon City, Philippines. The case arose from a complaint filed by 13-year-old Nanette de los Santos, who alleged that her father, Felipe, raped her. The complaint detailed that Felipe, using force and intimidation, took Nanette to a vacant apartment, undressed her, and had carnal knowledge of her against her will. Felipe de los Santos entered a plea of not guilty, and the trial proceeded with testimonies from Nanette, a medical doctor, and a barangay tanod.

Nanette testified that she had known Felipe as her father since her mother brought her to Manila when she was eight years old. On the night of the incident, after spending time with Felipe in his jeepney, he took her to an isolated apartment instead of going home. There, he coerced her into undressing and subsequently raped her. Followi...

Facts:

Background of the Victim

• Nanette de los Santos, born on November 15, 1980, was a minor at the time of the incident. She was raised by her mother, Cathy, after her father, Felipe de los Santos, left the family when she was very young. Nanette was brought to Manila at the age of eight, where she met Felipe, who was introduced as her real father.

The Incident

• On September 12, 1994, Nanette accompanied Felipe, a jeepney driver, on his route. After finishing work at midnight, they ate at a carinderia in General Avenue, Project 8, Quezon City. Instead of going home, Felipe took Nanette to an uninhabited apartment in the same area.
• Felipe instructed Nanette to buy cigarettes, soap, and coffee. After preparing the coffee, Felipe ordered Nanette to go upstairs, undress, and remove her underwear. Initially, Nanette resisted but eventually complied out of fear of maltreatment.
• Felipe then raped Nanette, inserting his organ into hers and mashing her breasts. He warned her not to tell anyone about the incident.

Aftermath

• The next day, Nanette fled their home and stayed with a friend, Evelyn. On October 6, 1994, with Evelyn's assistance, Nanette reported the rape to barangay tanod Nelson Bartolay, who recorded the complaint. Nanette was medically examined by Dr. Owen Lebaquin, who found evidence of healed lacerations on her hymen, consistent with sexual abuse.

Defense's Version

• Felipe denied the rape, claiming he was working as a stay-in driver/mechanic and was rarely home. He alleged that Nanette fabricated the story out of anger due to his disciplinary actions, including physical punishment for her refusal to attend school and her association with a "barkada."

Trial Court's Findings

• The trial court found Nanette's testimony credible, consistent, and corroborated by medical evidence. It rejected the defense's claims, noting that Felipe's version was contradicted by his wife, Cathy, and that the delay in reporting the rape was due to Nanette's fear of her father.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of the Victim's Testimony: The Court found Nanette's testimony credible, straightforward, and consistent with human experience. Her initial hesitation to report the rape was attributed to fear and intimidation, which is common in cases of incestuous rape. The Court emphasized that delay in reporting does not undermine the credibility of a rape victim, especially when the perpetrator is a person in a position of authority or moral ascendancy.

2. Moral Ascendancy and Intimidation: The Court recognized that Felipe exerted moral dominance over Nanette, using fear and intimidation to coerce her into submission. This psychological control explained Nanette's compliance with Felipe's orders and her initial silence about the abuse.

3. Defense's Motive Allegations: The Court rejected Felipe's claim that Nanette fabricated the rape charge out of retaliation. It held that no young girl would subject herself to the trauma of a public trial and medical examination unless the rape had actually occurred.

4. Award of Damages: The Court modified the trial court's award, increasing the indemnification to P75,000.00 in line with recent jurisprudence on rape cases. The award of P50,000.00 as moral damages was sustained, recognizing the psychological and emotional trauma suffered by the victim.

5. Constitutionality of the Death Penalty: While some members of the Court maintained their position that the death penalty under Republic Act No. 7659 is unconstitutional, they submitted to the majority ruling upholding its constitutionality.

Conclusion:

• The Supreme Court affirmed the conviction of Felipe de los Santos for the crime of rape, imposing the death penalty and ordering him to pay damages to the victim. The Court emphasized the credibility of the victim's testimony, the role of moral ascendancy in cases of incestuous rape, and the need for increased indemnification to reflect the gravity of the crime.