G.R. No. 130332 . May 31, 2000.
People of the Philippines, plaintiff-appellee, vs. Modesto Mamac y Caminero, accused-appellant.

FACTS

Accused-appellant Modesto Mamac was convicted of two counts of rape. He appealed only the conviction in Criminal Case No. 35,663-95, where he was sentenced to death for raping Bernadette Enguito on August 14, 1995. The prosecution evidence established that on that night, Mamac woke the 16-year-old Bernadette by poking her with a stick. When she looked, he was brandishing a bolo and ordered her outside, threatening to kill her family. He then brought her to a riverbank, forced her to undress at knifepoint, and raped her while holding the bolo to her neck.
Bernadette initially concealed the incident but later revealed it to her boyfriend and then to her mother, Segunda Enguito, leading to a police report and a medical examination. The medical findings showed a healed vaginal wound, easy penetration, and the presence of spermatozoa. The defense consisted of Mamac’s denial, claiming his advanced age of 64 rendered him incapable of sexual intercourse, and his assertion that there was no reason for Bernadette to falsely accuse him.

ISSUE

The core issue is whether the prosecution proved Mamac’s guilt for the crime of rape beyond reasonable doubt, particularly in light of the defense’s challenges to the credibility of the complainant’s testimony.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found Bernadette’s testimony credible, straightforward, and consistent on the material points of the rape. It dismissed the alleged inconsistencies, such as to whom she first reported the crime, as minor details that do not undermine her core narrative. The Court emphasized that there is no standard behavioral response to a traumatic event and that her fear, induced by the bolo and threats to her family, adequately explained her compliance and initial silence.
Regarding the imposable penalty, the Court held that the death penalty was improper. While the crime was committed after the effectivity of Republic Act No. 7659 , the qualifying circumstance of the victim being under eighteen (18) and the offender being a relative by consanguinity or affinity was not sufficiently alleged in the information. The information did not state Bernadette’s age, and although she referred to Mamac as her grandfather, the evidence showed he was not a biological relative but the common-law husband of her grandmother, and he himself stated he never treated her as a granddaughter. Thus, the qualifying circumstance was not proven. The proper penalty is reclusion perpetua. The Court increased the civil indemnity to P50,000.00 and awarded an additional P50,000.00 as moral damages.