People v. Sale
REITERATIONFacts
The Antecedents: The facts involve the elements of Rape under Philippine Law. Procedural History: The accused-appellant was charged in two informations alleging rape of his minor daughter. Upon arraignment he pleaded not guilty and trial ensued. On 1999-02-23 the Regional Trial Court, Branch 19, Cagayan de Oro City, found accused-appellant guilty of two counts of rape and imposed the death penalty and awards of civil indemnity and moral damages. The case was subjected to automatic review by the Supreme Court. The Petition: Accused-appellant appealed to the Supreme Court contending that the prosecution failed to prove guilt beyond reasonable doubt and that the testimony of the complainant was not credible and contained inconsistencies.
Issue(s)
Whether the testimony of the victim was sufficient to establish guilt beyond reasonable doubt despite alleged inconsistencies and her failure to shout for help during the commission of the crime. Whether the imposition of the death penalty is proper given the circumstances of the case.
Ruling
The Supreme Court En Banc AFFIRMED the decision of the Regional Trial Court finding accused-appellant guilty of two counts of incestuous rape and imposing the penalty of death for each count. The Court also affirmed the award of P150,000.00 as civil indemnity and P100,000.00 as moral damages (P75,000.00 and P50,000.00 per count respectively). The records were ordered forwarded to the Office of the President for possible exercise of the pardoning power. Costs de oficio.
Ratio Decidendi
On Issue 1: The Supreme Court held that the prosecution successfully proved guilt beyond reasonable doubt. Applying People v. Brondial and People v. Medina, the Court reiterated that a victim's credible and consistent testimony is sufficient for conviction in rape cases. The Court found the victim's testimony straightforward and convincing, noting she remained steadfast under rigorous cross-examination. Regarding the alleged inconsistencies about paydays, the Court ruled that these were minor details that do not impair the witness's credibility as they do not pertain to the essential elements of rape. On the failure to shout, the Court applied the doctrine from People v. Rabosa and People v. Corea, stating that there is no standard form of human behavioral response to trauma. The victim's silence was a natural result of her tender age, the 'moral ascendancy' of her father, and the lethal threats involving a hand grenade and a jungle knife. On Issue 2: The Court ruled that the imposition of the death penalty was mandatory under Article 335 of the Revised Penal Code (as amended by Republic Act (RA) 7659). The elements for qualified rape were present: (1) the victim was under eighteen (18) years of age; and (2) the offender was the victim's parent. Both facts were alleged in the information and proven during trial through the victim's birth certificate and the accused's own admissions of paternity. Although four members of the Court maintained their view that the death penalty is unconstitutional (citing People v. Echegaray), they submitted to the majority's ruling that the law is constitutional and must be applied. The Court also increased the civil indemnity to P75,000.00 and moral damages to P50,000.00 per count, in line with prevailing jurisprudence.
Main Doctrine
The credible, consistent and corroborated testimony of a rape victim may suffice to sustain a conviction for rape; where the victim is a minor and the offender is a parent, the offense qualifies under Article 335 of the Revised Penal Code as amended by Republic Act No. 7659, justifying the imposition of the penalty provided therein.