People v. Daco
REITERATIONFacts
The Antecedents: Accused-appellant Salvador C. Daco was charged with seven (7) counts of qualified rape against his own daughter, AAA, who was thirteen (13) years old at the time of the first offense. The alleged rapes occurred on different dates from October 7, 1999, to April 2000. Procedural History: The Regional Trial Court (RTC) of San Jose, Camarines Sur, Branch 30, found the accused-appellant guilty beyond reasonable doubt of seven (7) counts of qualified rape and sentenced him to suffer the death penalty for each count, with awards for civil indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction with modifications, increasing moral damages and adding exemplary damages. The case was elevated to the Supreme Court for automatic review due to the death penalty. The Petition: The accused-appellant raised errors concerning the lower courts' findings of guilt beyond reasonable doubt and the weight given to his defense.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt. Whether the lower courts erred in not giving exculpatory weight to the defense interposed by the accused-appellant. Whether the penalty imposed and the damages awarded were proper.
Ruling
The decision of the Court of Appeals was affirmed with modifications. The accused-appellant was sentenced to reclusion perpetua without eligibility for parole, and ordered to pay civil indemnity, moral damages, and exemplary damages for each of the seven counts of rape.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court found that the victim's testimony, despite minor inconsistencies, was consistent on the basic matters constituting the elements of rape and the positive identification of the accused-appellant. The Court emphasized that minor discrepancies in details do not impair credibility, especially in cases of rape involving a young victim recounting a traumatic experience. The medico-legal findings corroborated the victim's testimony regarding repeated sexual intercourse. The Court also dismissed the defense's claim of fabricated charges due to resentment as a lame and flimsy defense, stating that parental punishment is insufficient motivation for a daughter to falsely accuse her father of rape, especially when it carries the death penalty and brings shame upon the family. The Court reiterated that the youth and immaturity of a rape victim are generally badges of truth, and it is inconceivable for a daughter to accuse her father of such a crime if it were untrue, as it would mean a lifetime of dishonor. The Court found the victim's testimony to be straightforward, candid, and unshaken by cross-examination, deserving full faith and credence. On the issue of the defense interposed by the accused-appellant: The Court found the defense's claim that the charges were fabricated due to resentment over disciplinary action to be a weak and unbelievable defense. The Court reasoned that parental punishment, even if it involved striking the daughter, is not a sufficient motive for a child to falsely accuse a parent of rape, particularly when such an accusation carries severe consequences like the death penalty and societal shame. The Court highlighted that it takes extreme depravity for a young girl to concoct such a story. The Court also noted that the defense's assertion that the victim was motivated by ill will was not supported by substantial evidence and was contradicted by the victim's consistent and credible testimony. The Court reiterated its stance that family resentment or revenge has never swayed it from giving credence to a rape complainant's testimony, especially a minor who remains steadfast throughout the proceedings. On the issue of the penalty imposed and damages awarded: The Court affirmed the imposition of penalties and damages, with modifications based on prevailing laws. The Court noted that under Article 266-B of the Revised Penal Code, as amended by R.A. No. 8353, the death penalty was prescribed for rape committed by a parent on a victim under eighteen years of age. However, in view of the passage of R.A. No. 9346, which prohibits the imposition of the death penalty, the Court modified the sentence to reclusion perpetua without eligibility for parole. The Court also affirmed the award of P75,000.00 as civil indemnity for each count, consistent with jurisprudence that increased indemnity when the death penalty would have been authorized. The Court agreed with the CA's increase of moral damages to P75,000.00 and the award of P25,000.00 as exemplary damages for each case, aligning with prevailing jurisprudence on damages in rape cases.
Main Doctrine
The concurrence of the minority of the victim and her relationship with the offender (parent) is a special qualifying circumstance for rape, prescribing the penalty of death under R.A. No. 8353. However, with the passage of R.A. No. 9346, the penalty is now reclusion perpetua without eligibility for parole. Civil indemnity and moral damages are awarded, with exemplary damages also granted.