People v. Yaoto
REITERATIONFacts
The Antecedents: Accused-appellant Eduardo Yaoto was charged with two counts of rape against his daughter, Angeline Yaoto, who was 17 years old at the time of the incidents. The first incident occurred on June 2, 1997, where the accused allegedly hit Angeline with a belt, tied her hands, undressed her, mashed her breasts, kissed her, and had sexual intercourse with her against her will. Following this, the accused allegedly kept watch on Angeline, followed her to the comfort room, and chained her when he went out. The second incident occurred on June 7, 1997, where the accused allegedly lay beside Angeline, touched her thighs, whispered his intention to have sexual intercourse, mauled her when she refused, tied her feet, undressed her, and again had sexual intercourse with her. Angeline escaped after the second incident and reported the assaults to the police. Medico-genital examination revealed genital and extragenital injuries, including lacerations on the fourchette and hymen. Procedural History: The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt of two counts of rape and sentenced him to death for each count, ordering him to indemnify the victim P50,000.00 for each case. The case was elevated to the Supreme Court for automatic review. The Petition: Accused-appellant assailed the trial court's decision, questioning the credibility of the complainant's testimony, the weight given to his own testimony, and the imposition of the death penalty. He argued that certain details in Angeline's testimony were improbable, such as the removal of clothing while she was tied, the duration of erection, and the alleged guarding and chaining. He also questioned the failure to present physical evidence and attributed the genital lacerations to her boyfriend. The Supreme Court affirmed the conviction for rape but modified the penalty.
Issue(s)
Whether the trial court erred in giving full credence to the testimony of the complainant. Whether the trial court erred in not giving weight to the testimony of the accused. Whether the trial court erred in imposing the death penalty.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for two counts of rape but modified the penalty. The death penalty was set aside, and the accused-appellant was sentenced to suffer the penalty of reclusion perpetua for each count. The award of civil indemnity was maintained at P50,000.00 per count, and an additional P50,000.00 was awarded as moral damages for each count. Exemplary damages were not awarded due to the failure to allege the aggravating circumstance of relationship in the Information.
Ratio Decidendi
On the credibility of the complainant's testimony: The Court found Angeline Yaoto's testimony to be clear, positive, and reliable. The accused-appellant's arguments regarding the improbability of certain acts, such as removing clothing while tied or the duration of erection, were dismissed as mere assumptions not supported by evidence. The Court clarified that the term "ililis" meant to roll up or lift up, not necessarily complete removal of clothing, consistent with the testimony that her dress was put back on. The Court also noted that the accused-appellant's own behavior, such as guarding Angeline with weapons and chaining her, was more unnatural than hers. The failure to present physical evidence like the rope or bolo did not diminish the credibility of Angeline's testimony, as the prosecution is not bound to present all available evidence. The Court reiterated that no woman would fabricate a story of defloration and submit to public humiliation and scrutiny if the tale were not true, especially in cases of incestuous rape. On the weight given to the accused's testimony: The Court found no merit in the accused-appellant's claims. His denial and attempts to discredit Angeline's testimony by attributing the injuries to her boyfriend were unconvincing. The Court emphasized that whether Angeline had sexual intercourse with her boyfriend was inconsequential; the fact remained that the accused-appellant had carnal knowledge of his daughter without her consent. The trial court's assessment of Angeline's credibility, based on her demeanor and candor on the witness stand, was given significant weight and not disturbed. On the imposition of the death penalty: The Court agreed with the accused-appellant that the death penalty was improperly imposed. While the victim was under 18 years of age, the Information failed to allege the aggravating circumstance of the offender being a parent or ascendant. The Court held that the failure to allege this relationship in the Information, concurrently with the minority of the victim, barred conviction for rape in its qualified form, as it violated the accused's right to be fully informed of the charges against him. Consequently, the conviction was for simple rape, and the penalty was modified from death to reclusion perpetua for each count. The Court also noted that moral damages should be awarded in rape cases, as trauma is inherent, and exemplary damages could not be awarded because the aggravating circumstance of relationship was not alleged.
Main Doctrine
The failure to allege in the information the relationship of the offender to the victim, concurrently with the minority of the victim, bars conviction for rape in its qualified form, even if the qualifying circumstance of minority was alleged. In such cases, the offender should be convicted of simple rape.