Case Summary (G.R. No. 128085-87)
Charges and Context of Offense
Benjamin Razonable was charged with three counts of rape against his daughter, Maria Fe Razonable, with the allegations indicating the incidents occurred in the year 1987. Each charge detailed that Maria Fe was subjected to forcible carnal knowledge against her will, with the allegation of a relationship heightening the severity of the crimes.
Details of the Incidents
The first incident occurred during the middle of June 1987 when Maria Fe, then 12 years old, was in her room. Her father forced himself upon her, covering her mouth and inflicting violence in the progression of the act. Similar occurrences transpired on subsequent nights, with Razonable threatening her with death should she disclose these events. Maria Fe only reported her father's actions to her elder sister in February 1993, motivated by growing fear of further assaults.
Defense and Testimony
The defense of Razonable relied on alibi and denial, asserting that during the alleged times, he was working at a bakery. A witness supported this claim; however, inconsistencies arose during cross-examination revealing gaps in his account. Razonable also attempted to suggest that Maria Fe had ulterior motives for her accusations, citing his disciplinary actions as a potential reason for her claims.
Judgment and Rationale
The trial court found Razonable guilty on all counts, emphasizing the gravity of the relationship between the victim and the perpetrator as an aggravating circumstance. The defense’s arguments focusing on the vagueness of the dates in the information were rejected because Razonable failed to raise such claims appropriately during the trial. The court noted that the circumstances surrounding the threat of violence and the familial relationship created an environment of intimidation that severely impacted Maria Fe’s ability to act.
Credibility of the Victim
The Supreme Court reaffirmed the trial court's findings that Maria Fe's credibility was intact and bolstered, considering the deep emotional trauma a victim of incest faces. Factors such as the nature of the familial relationship and the psychological domination exerted by Razonable were acknowledged as critical in establishing Maria Fe’s ordeal.
Legal Framework
The decision was grounded in the 1987 Philippine Constitution and applicable laws that pertain to the definition and prosecution of rape, considering aggravating circumstances inherent in the relationship between the victim and the accused. The penalties defined included reclusion perpetua for each count of rape, alongside moral damages.
Adjustments on Damages Awarded
While affirming the convictions, the Supreme Court modified the
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Case Background
- This case is an appeal from a decision by the Regional Trial Court of Camarines Norte, Branch 39, dated May 3, 1996.
- Accused Benjamin Razonable was found guilty beyond reasonable doubt of raping his daughter, Maria Fe Razonable.
- He received a sentence of three counts of reclusion perpetua and was ordered to pay P200,000.00 as moral damages.
Charges and Allegations
- Razonable was charged in three separate Informations with the crime of rape, all worded identically.
- The crimes were alleged to have occurred "sometime in the year 1987" at their residence in Daet, Camarines Norte.
- The charges included aggravating circumstances: relationship (as father of the victim) and commission of the offense in their dwelling.
Facts of the Case
- On multiple occasions in June 1987, Razonable allegedly raped his 12-year-old daughter, Maria Fe, who was living alone with him due to her parents' separation.
- The first incident occurred when Razonable forcibly entered Maria Fe's room, threatened her, and proceeded to have carnal knowledge of her while covering her mouth.
- This abusive pattern continued on subsequent nights, with Maria Fe subjected to further assaults while being threatened with death if she disclosed the incidents.
Victim's Testimony and Medical Evidence
- Maria Fe only revealed the incidents to her elder sister in February 1993, driven by her conscience and fear of further abuse.
- She