In People v. Dela Cruz, the Supreme Court affirmed the conviction of a father for the crimes of rape and acts of lasciviousness against his minor daughter. The Court emphasized that the daughter’s positive identification of her father as the perpetrator, along with corroborating testimony and medical evidence, outweighed the father’s denial and allegations of ill motive. This ruling underscores the judiciary’s commitment to protecting children from sexual abuse, even when the perpetrator is a family member, and reinforces the principle that familial relationships do not grant immunity from prosecution for heinous crimes.

Broken Trust: Can a Father’s Actions Shatter Legal Defenses in Incest Cases?

This case revolves around the accusations of AAA against her father, Renato dela Cruz, for incidents occurring in October 1999 and September 2003. AAA testified that in 1999, her father kissed and touched her private parts when she was just eleven years old. Later, in 2003, he forcibly had carnal knowledge of her. Her elder sister, BBB, witnessed the latter incident, further supporting AAA’s claims. The accused-appellant denied these charges, claiming that AAA and BBB had ill motives due to his relationship with another woman. The central legal question is whether the prosecution successfully proved beyond reasonable doubt that Renato dela Cruz committed the crimes of rape and acts of lasciviousness against his daughter, AAA, despite his defenses.

The prosecution presented AAA’s detailed account of the sexual abuse she endured, which the lower courts found credible and consistent. BBB’s testimony corroborated AAA’s version of events, particularly the incident in September 2003. Furthermore, the medico-legal report indicated that AAA was in a “non-virgin state physically,” lending further weight to the prosecution’s case. The accused-appellant’s defense relied heavily on denying the acts and alleging that AAA and BBB were motivated by ill will. He argued that inconsistencies in AAA’s testimony and their admitted animosity toward him should cast doubt on their credibility. However, the courts a quo found these arguments unpersuasive, emphasizing that positive identification and credible testimony from the victim can outweigh a simple denial.

The Court, in its analysis, referred to relevant provisions of the Revised Penal Code. Article 266-A defines rape by sexual intercourse:

ART. 266-A. Rape, When and How Committed. – Rape is committed –

1. By a man who shall have carnal knowledge of a woman under any of the following circumstances:

a. Through force, threat or intimidation;

b. When the offended party is deprived of reason or is otherwise unconscious;

c. By means of fraudulent machination or grave abuse of authority;

d. When the offended party is under twelve (12) years of age or is demented, even though none of the circumstances mentioned above be present.

The elements needed to prove rape are carnal knowledge and that the act was committed through force, threat, or intimidation; or the victim was unconscious; or the victim was under 12 years old. Similarly, the Court referenced Article 336, which defines acts of lasciviousness:

ART. 336. Acts of lasciviousness.- Any person who shall commit any act of lasciviousness upon other persons of either sex, under any of the circumstances mentioned in the preceding article, shall be punished by prision correccional.

The elements of acts of lasciviousness are: an act of lewdness is committed, the act is done under circumstances like force or intimidation, and the offended party is another person. The Court noted that the lower courts rightly gave more weight to AAA’s testimony. In Dizon v. People, the Supreme Court emphasized the importance of the trial court’s assessment of witness credibility, particularly when the trial court has the unique opportunity to observe the demeanor of a witness and is in the best position to discern whether they are telling the truth.

Jurisprudence instructs that when the credibility of a witness is of primordial consideration, as in this case, the findings of the trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded respect if not conclusive effect. This is because the trial court has had the unique opportunity to observe the demeanor of a witness and was in the best position to discern whether they were telling the truth. When the trial court’s findings have been affirmed by the appellate court, as in the present case, said findings are generally binding upon this Court.

The accused-appellant also argued that alleged inconsistencies in AAA’s testimony undermined her credibility. However, the Court found that AAA clarified the conflicting statements during cross-examination, demonstrating that no actual rape occurred in October 1999, but rather acts of lasciviousness. The court cited Dizon v. People again stating that in rape cases, the complainant’s testimony must be considered and calibrated in its entirety, not in truncated or isolated passages.

Furthermore, the Court underscored that the ill motives alleged by the accused-appellant were insufficient to discredit the victim’s testimony. In People v. Balunsat, the Supreme Court observed that it is unlikely for a young girl and her family to falsely accuse a blood relative of rape, especially given the social stigma associated with such accusations. Given AAA’s age and her familial relationship with the accused-appellant, the rape was qualified under Article 266-B of the Revised Penal Code:

Art. 266-B. Penalties. – x x x.

The death penalty shall also be imposed if the crime of rape is committed with any of the following aggravating/qualifying circumstances:

1. When the victim is under eighteen (18) years of age and the offender is a parent, ascendant, stepparent, guardian, relative by consanguinity or affinity within the third civil degree, or the common-law spouse of the parent of the victim.

While Article 266-B prescribes the death penalty, Republic Act No. 9346 prohibits the imposition of the death penalty, mandating reclusion perpetua instead. The court thus affirmed the Court of Appeals’ imposition of reclusion perpetua for the rape conviction. The Supreme Court also adjusted the monetary awards granted to AAA. While affirming the civil indemnity and moral damages for the rape conviction, the Court also reduced the civil indemnity for acts of lasciviousness from P50,000.00 to P20,000.00 and additionally awarded moral and exemplary damages. This adjustment reflects the current jurisprudence on damages in similar cases.

FAQs

What were the two crimes the accused-appellant was charged with?	The accused-appellant was charged with two counts of rape, one allegedly committed in October 1999 and another in September 2003. The court ultimately convicted him of rape for the September 2003 incident and acts of lasciviousness for the October 1999 incident.
What was the basis for the accused-appellant’s defense?	The accused-appellant primarily denied the acts and claimed that the victim and her sister had ill motives due to his relationship with another woman. He also pointed to alleged inconsistencies in the victim’s testimony.
What evidence did the prosecution present?	The prosecution presented the testimony of the victim, AAA, who detailed the sexual abuse she endured. They also presented the testimony of AAA’s sister, BBB, who witnessed one of the incidents, and a medico-legal report indicating that AAA was not a virgin.
Why did the court give more weight to the victim’s testimony?	The court found AAA’s testimony to be credible and consistent, and her positive identification of the accused-appellant as the perpetrator was compelling. The court also considered the corroborating testimony of BBB and the medico-legal report.
What is the significance of the relationship between the accused-appellant and the victim?	The fact that the accused-appellant was the victim’s father qualified the rape, as the victim was under 18 years old and the offender was her parent. This would have prescribed the death penalty, but R.A. 9346 prohibits the imposition of the death penalty, mandating reclusion perpetua instead.
What penalties were imposed on the accused-appellant?	For the rape conviction, the accused-appellant was sentenced to reclusion perpetua, in lieu of death, and ordered to pay civil indemnity, moral damages, and exemplary damages. For the acts of lasciviousness conviction, he was sentenced to imprisonment ranging from six months to six years and also ordered to pay civil indemnity, moral damages, and exemplary damages.
How did the Supreme Court modify the Court of Appeals’ decision?	The Supreme Court affirmed the Court of Appeals’ decision with modifications by reducing the civil indemnity for the acts of lasciviousness conviction from P50,000.00 to P20,000.00 and awarding moral and exemplary damages.
What legal principles did the Supreme Court emphasize in this case?	The Supreme Court emphasized the importance of the trial court’s assessment of witness credibility, particularly when the victim positively identifies the perpetrator. The Court also underscored that ill motives are inconsequential if there is an affirmative and credible declaration from the rape victim, which clearly establishes the liability of the accused.

The People v. Dela Cruz case serves as a stark reminder of the devastating impact of incestuous abuse and the legal system’s resolve to hold perpetrators accountable. The Court’s decision reinforces the importance of protecting vulnerable individuals, especially children, from sexual exploitation and ensuring that justice is served.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Dela Cruz, G.R. No. 192820, June 04, 2014