GR 129052; (May, 2000) (Digest)
G.R. No. 129052 May 31, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUSEBIO TRAYA Y QUEMADA, accused-appellant.
FACTS
The accused-appellant, Eusebio Traya, was charged with the rape of his 16-year-old daughter, Eulyn Traya. The prosecution established that the sexual abuse began in August 1995 and was repeated multiple times per week in their one-room hut. Eulyn’s younger sister, Liezl, witnessed one incident but was too afraid to intervene. In September 1996, Eulyn discovered she was pregnant, and she eventually gave birth to a child who died days later. After the baby’s death, Liezl revealed to their half-sister, Marites Guimlan, that the father was their own father, leading to a report to authorities and the filing of a complaint.
During trial, the appellant, while initially pleading not guilty, made a judicial admission. He acknowledged having carnal knowledge with his daughter on multiple occasions, though he claimed she consented while he was drunk. The Regional Trial Court convicted him of rape and imposed the death penalty, prompting this automatic review.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.
RULING
Yes, the accused-appellant is guilty beyond reasonable doubt. The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court found the victim’s testimony credible, straightforward, and consistent. It emphasized that testimonies of child-victims of rape are given full weight and credit. The appellant’s defense of consent was rejected as inherently incredible; no daughter in her right mind would willingly submit to her father. The Court also noted that delay in reporting the crime, attributed to the victim’s fear and the appellant’s threats, does not undermine credibility, especially in incestuous rape cases where the offender exercises moral ascendancy and control.
The legal logic is anchored on the principle that the lone testimony of a rape victim, if credible, is sufficient for conviction. The appellant’s own judicial admission corroborated the charge. However, the death penalty was reduced because the Information failed to allege with specificity the victim’s minority (being under eighteen) and the appellant’s relationship as a parent, which are qualifying circumstances for the imposition of the death penalty under Republic Act No. 7659 . The Court treated these as generic aggravating circumstances, warranting reclusion perpetua. The appellant was also ordered to pay moral and exemplary damages.