G.R. No. 197458 - Pinlac y Resolme vs. People

The case involves an allegation of incestuous rape, where the appellant, Enerio Ending y Onyong, is accused of raping his own daughter (designated as aAAAa).
The indictment was based on three separate Informations which, aside from the dates of occurrence, were similarly worded. Each Information charged appellant with committing rape against his daughter on different occasions.
The crimes, committed between January 2000 and January 2001, took place in various locations including a residential setting, a copra drier, and a pasture area within Misamis Occidental.

The victim, aAAAa, testified that on the day of the National Elementary Achievement Test (NEAT), she was rudely awakened and subsequently assaulted by her father in her own room.
She recounted that on January 18, 2000, after performing her morning routine, her father unexpectedly entered her room, forcibly removed her towel, and committed the rape by inserting his penis into her vagina.
A second incident occurred in the fourth week of January 2000 when, while helping with household chores at her grandfather’s copra drier, she was again forcibly assaulted under threat.
A third incident was described on January 2, 2001, when she went to help herd cattle; there, her father assaulted her near a rock, forcibly removing her clothing and threatening her life if she disclosed the incident.
The victim delayed disclosing the assaults due to her father’s threats—specifically the threat of death—and because her mother was not present at the time, leaving her feeling isolated and fearful.
A medical examination substantiated her account by revealing old lacerations in her private parts, echoing the physical evidence of repeated abuse.

The appellant testified solely in his own behalf, offering an explanation that minimized the alleged incidents and cast doubt on the veracity of his daughter’s testimony.
He contended that his daughter, for reasons including alleged personal animosity (stemming from an earlier disciplinary incident), fabricated the charges.
Furthermore, he claimed an alibi by stating that at the time of the assaults, aAAAa was residing with her grandparents—alleging that the geographical separation made it implausible for him to have been present at all the crime scenes.
His defense heavily relied on denial and the assertion of an alibi, without presenting corroborative evidence or witnesses to support his claims.

At the Regional Trial Court (RTC), the extensive and consistent testimony of the victim, supported by physical evidence and corroborative circumstantial evidence, led to a conviction of appellant for three counts of rape.
The RTC imposed the death penalty for each count, following the finding of the special qualifying circumstances of minority (the victim being 15 years old) and the relationship of consanguinity.
The appellant’s appeal led to a review by the Court of Appeals (CA), which affirmed the RTC’s judgment but, due to the constitutional proscription on the death penalty (as per RA No. 9346), reduced the penalty to reclusion perpetua and adjusted the awarding of exemplary damages and other indemnities.

The proximity between the appellant’s residence and that of the victim’s grandparents (approximately 7–12 kilometers) was noted, undermining his alibi claim that he could not have been present at the locus delicti.
The consistency in the victim’s narrative—detailing the assault in varied but familiar settings (home, copra drier, and pasture)—reinforced the credibility of her testimony.
The judicial findings emphasized that mere denial, if unsubstantiated by clear and convincing evidence, does not overcome the weight of a positive identification by a rape victim and the body of circumstantial evidence.

Whether the trial court’s findings on the credibility of a witness, particularly the victim’s testimony, were sufficient to establish guilt beyond reasonable doubt.
Whether the appellate court was correct in giving deference to the trial court’s evaluation of credibility absent any clear error in the findings.

Whether the appellant’s defense, which relied solely on denial and an alibi based on the victim’s temporary residence with her grandparents, had any merit.
Whether the geographical distance claimed by the appellant effectively precluded his presence at the scene of the crimes.

Whether the allegations and subsequent evidence sufficiently established the special qualifying circumstances – specifically, the victim’s minority and the familial relationship between the appellant and the victim.
Whether the inclusion of these circumstances warranted the imposition of the death penalty, notwithstanding the later legal prohibition and subsequent sentencing adjustments.

Whether the modification of the penalty from death to reclusion perpetua was correctly applied in light of the prohibition on the death penalty.
Whether the civil indemnity, moral damages, exemplary damages, and the imposition of interest were properly computed and awarded.