G.R. No. 131636 - People vs. Invencion y Soriano

Artemio Invencion y Soriano was charged with thirteen counts of rape involving his 16-year-old daughter, AAA. These charges were consolidated and tried under Criminal Cases Nos. 9363 to 9375 before the Regional Trial Court (RTC) of Tarlac, Branch 65.
Artemio pleaded not guilty to all charges at arraignment.

Witness Elven Invencion, Artemio’s 8-year-old son by his second common-law wife, testified that he saw Artemio on top of AAA performing a “pumping motion” inside their house one night before the end of the 1996 school year. He also described Artemio as a strict, cruel, and drunken father who prohibited AAA from seeing suitors and was abusive towards him.
Eddie Sicat, a farmer and neighbor, testified that between 6:00 and 7:00 a.m. one day in the second week of March 1996, he saw Artemio on top of AAA making a pumping motion through a hole in the sawali wall of their house. He immediately reported this to Artemio’s stepfather, Celestino Navarro.
Gloria Pagala, AAA’s mother and Artemio’s former common-law wife, testified regarding their family background and that AAA lived with Artemio after Artemio’s mother’s death in 1996. She narrated that on 30 August 1996, her son informed her of AAA's pregnancy, and upon inquiry, AAA confessed to being sexually abused by Artemio. Gloria reported this to the National Bureau of Investigation (NBI).
Dr. Rosario Fider from Tarlac Provincial Hospital examined AAA on 16 September 1996 and found her about five to six months pregnant, with healed incomplete hymenal lacerations consistent with sexual intercourse or insertion of a foreign body.
Atty. Florencio Canlas, an NBI agent, recorded a sworn statement from AAA on 18 September 1996, wherein AAA complained of being raped by Artemio.

Artemio did not testify. Instead, his counsel de parte, Atty. Isabelo Salamida, testified that on 24 June 1997, he observed Artemio’s house, noting the door was padlocked, windows shut, and interior dark at about 11 a.m. He argued that Eddie Sicat’s testimony was false and impossible because one could not have seen the act through the walls given the darkness and structure of the hut.

Gloria Pagala rebutted the defense, stating that the sawali walls of the hut were partially destroyed with holes as of December 1995 and still unrepaired as of September 1996, allowing visibility into the room.
Celestino Navarro, Artemio’s stepfather and owner of the house, confirmed the existence of holes in the sawali walls during Artemio's residence. He stated that after Artemio’s arrest, he repaired these holes using galvanized iron sheets.

The RTC convicted Artemio on the charge in Criminal Case No. 9375 and sentenced him to death, awarding moral and exemplary damages to AAA, but acquitted him in the other twelve counts for lack of evidence.
Artemio challenged the trial court’s ruling, attacking the credibility and competency of the witnesses and contesting the sufficiency of evidence to prove his guilt beyond reasonable doubt. He also questioned the imposition of the death penalty.

Whether or not the prosecution witnesses, especially the 8-year-old Elven Invencion, were competent and credible to testify against Artemio.
Whether the prosecution sufficiently proved Artemio’s guilt beyond reasonable doubt of the crime of rape.
Whether the alleged inconsistencies in the testimonies of prosecution witnesses are sufficient to create reasonable doubt.
Whether the penalty of death was properly imposed considering the lack of clear proof of the victim’s minority.
Whether the amounts awarded as moral and exemplary damages, and the absence of civil indemnity, were proper.