Case Summary (G.R. No. 145226)
Background of the Case
The case arises from a series of accusations against William Alpe for the crime of qualified rape as defined under Article 335 of the Revised Penal Code. The Regional Trial Court of Naga City, Branch 28, convicted Alpe on December 8, 1997, imposing the death penalty and awarding moral damages to the victim. The prosecution's accusations detail that, during several incidents, Alpe sexually assaulted his daughter, Mary Joy, who was only fourteen at the time.
Incident Description and Evidence Presented
The timeline established that the first incident occurred in January 1995, when Alpe allegedly assaulted Mary Joy while the family was sleeping in their one-room house. Mary Joy testified that she was awakened by Alpe’s actions as he removed her clothing and raped her. Despite her attempts to resist, she was overpowered, and Alpe threatened her not to disclose the incident. Upon awakening, the victim's mother, Virginia Alpe, witnessed the assault and intervened, prompting a violent confrontation with Alpe.
Mary Joy later disclosed to her mother that this was not an isolated incident, revealing that she had been raped multiple times prior, all while her mother was away from home. Medical examinations corroborated the claims of sexual abuse, showing evidence consistent with rape.
Legal Findings
The trial court concluded that the evidence presented established Alpe’s guilt beyond a reasonable doubt. Key factors included the corroborative testimonies from both Mary Joy and Virginia Alpe, along with forensic evidence from the medical examination that indicated a healed hymenal laceration consistent with the alleged assaults.
Appellant's Arguments
In appeal, Alpe contended that the trial court erred in its conviction due to perceived discrepancies in the victim's reporting of the incidents, particularly the delay in disclosing the abuse. He also cited the presence of anatomical anomalies as a reason to doubt the occurrence of rape. However, the court dismissed these arguments, emphasizing that the fear instilled by Alpe’s threats inhibited Mary Joy from reporting the abuse before she did eventually.
Court's Rationale and Decision
The Supreme Court upheld the conviction, highlighting the fact that the age of the victim and the familial relationship between the victim and the accused warranted the imposition of the death penalty under the law. The court acknowledged the established legal precedent that a delay in reporting incidents of incestuous rape does not undermine the credibility of th
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Case Overview
- This case involves the automatic review of a judgment rendered by the Regional Trial Court of Naga City, Branch 28, on December 8, 1997, in Criminal Case No. RTC'95-6000.
- William Alpe y Cuatro was convicted of qualified rape of his daughter, Mary Joy Alpe, who was 14 years old at the time of the offense.
- The trial court sentenced the accused to death and ordered him to pay moral damages amounting to P50,000.00.
Charges and Proceedings
- The accusatory Information stated that in January 1995, in Gainza, Camarines Sur, William Alpe used violence and intimidation to have carnal knowledge of his daughter against her will.
- Upon arraignment on July 8, 1997, the appellant pleaded "not guilty."
- The prosecution summarized the evidence, detailing the living conditions of the family and the circumstances surrounding the incident.
Evidence Presented
- The prosecution's case included testimonies from Mary Joy and her mother, Virginia Alpe.
- Virginia Alpe testified that she was awakened by her daughter's cries, witnessing the accused on top of Mary Joy.
- Mary Joy described the assault in detail, including the physical pain she experienced and her father's threats against he