People v. Buison
REITERATIONFacts
The Antecedents: Adelina T. Buison, aged 15, was a toddler when abandoned by her father, accused Vicente Buison, who left her mother for another woman; after over 10 years, they reunited in Victorias, Negros Occidental on 17 May 1991, where Adelina, thrilled, embraced him tearfully and insisted on joining him in General Santos City despite his suggestion to stay with uncle Rodrigo in Davao, forgetting to seek permission from her mother and grandfather in Talisay. Three months later, on 15 August 1991 at 9:00 PM, while sleeping on the floor of her father's shanty with two minor stepsisters, Adelina awoke to her naked father mounting her, forcing penile insertion despite her punches and screams muffled by his hand, consummating in three minutes; he laughed, noting her virginity, devastating her. At dawn 16 August 1991, he repeated the assault, stripping and ravishing her again despite protests; she slept naked from exhaustion but concealed it due to death threats. That evening around 9:00 PM, he undressed before her, kissed her body, and raped her third time. On 25 October 1991, en route to Davao in a truck convoy to confide in uncle Rodrigo, accused dismissed the helper, poked a knife, and raped her inside the truck, then returned to General Santos instead. Unable to endure, she fled to godmother Fely Bartiana, who took her to DSWD for filing complaints; medico-legal exam showed vaginal scars at 5:00 and 8:00 positions consistent with penile trauma, no semen. Procedural History: Accused charged with four counts of rape before RTC-Br. 11, General Santos City; trial court convicted him as charged, sentencing reclusion perpetua per count, P50,000 moral damages total, and costs, crediting Adelina's testimony over alibi/denial, rejecting revenge motive. The Petition: On appeal, accused argued guilt not proven beyond reasonable doubt, claiming Adelina's resentment from childhood abandonment and lack of support motivated fabrication; alibi—he was on Davao trips 15-16 August (with helper Bonnie Bantacalo) and left her home 25 October; wife Mila testified family presence precluded opportunity, Adelina resented discipline as they didn't raise her; implausibility of her accompanying him post-rapes or not fleeing earlier.
Issue(s)
Whether accused's guilt for four counts of rape was proven beyond reasonable doubt, considering defenses of alibi, denial, and imputed revenge motive. Whether the trial court's credibility assessment, penalty, and damages imposition were proper.
Ruling
Decision affirmed with modification: guilty beyond reasonable doubt of four counts of rape; reclusion perpetua per count upheld (crimes pre-RA 7659 effectivity); moral damages P50,000 per count confirmed; additional P50,000 civil indemnity per count awarded; costs against accused.
Ratio Decidendi
On Issue 1: The Supreme Court meticulously scrutinized the evidence, giving full faith and credence to Adelina's positive, categorical, consistent, and straightforward testimony detailing each rape's circumstances—dates, times, methods (force, muffling screams, knife), dialogue, and aftermath—corroborated by medico-legal findings of healed hymenal scars at 5:00 and 8:00 positions indicative of penile penetration, establishing consummated rape under Art. 335 RPC (carnal knowledge of daughter under 12 not applicable as she was 15, but force/intimidation proven). Accused's alibi for 15-16 August (Davao trip returning 2:00 PM 16th) and 25 October (left her home) rejected as trial court found it physically possible for evening assaults post-return, and truck helper's testimony deemed biased/rebutted by victim's specifics; denial and bare revenge imputation (resentment over abandonment/discipline) failed per People v. Gagto (G.R. No. 113345, 9 Feb 1996), as family grudges do not negate steadfast minor victim's narration under grueling cross-examination. Moral ascendancy of father over minor daughter in unfamiliar locale substituted for violence/intimidation (People v. Lutao doctrine implied), explaining non-resistance, delayed escape, and continued exposure (hoping for uncle's aid, fearing death threats, no trusted allies like stepmother/neighbors). Implausibilities (accompanying post-rapes, not immediate flight) bolstered credibility, reflecting naivete, paternal longing shattered by betrayal, and isolation—consistent with human experience in incest cases. Biased defense witnesses (wife, helper) naturally favored accused, yielding to victim's untainted account; post-arrest mollification attempts by accused's family confirmed guilt consciousness. On Issue 2: Penalty of reclusion perpetua proper per RA 7659 (effective 30 Dec 1993, applicable as crimes 1991 but penalty raised pre-RA 8353); damages modified per prevailing jurisprudence (e.g., multiple awards standardized at P50,000 civil indemnity ex delicto per rape for vindication of violated chastity, plus P50,000 moral damages per count for suffering, totaling P100,000 per count).
Main Doctrine
The testimony of a rape victim, especially a minor daughter against her father, deserves full credence when categorical, consistent, and corroborated by medical evidence, prevailing over alibi and denial defenses which require clear proof of physical impossibility of presence at the crime scene. In incestuous rapes, the parent's moral ascendancy and authority exert coercive influence equivalent to force or intimidation, eliminating any notion of consent and compelling the victim to endure repeated assaults due to fear of reprisal and lack of alternatives. Defenses imputing fabricated charges due to family resentment or revenge fail unless they obliterate the crime's elements, as steadfast victim narration under direct and cross-examination remains unassailable. Seemingly implausible victim behavior, such as accompanying the accused post-assault or delaying complaint, is sufficiently explained by naivete, hope for paternal affection, threats, and isolation, bolstering rather than detracting from credibility. Consistent with jurisprudence, each consummated rape warrants reclusion perpetua (pre-RA 8353), P50,000 civil indemnity ex delicto, and P50,000 moral damages per count.