G.R. No. 168650 ; October 26, 2007
PEOPLE OF THE PHILIPPINES, appellee, vs. JOSE TUAZON, appellant.

FACTS

The appellant, Jose Tuazon, is the stepfather of the private complainant, AAA. The prosecution alleged that he raped AAA on multiple occasions, beginning in 1995 when she was 11 years old and a Grade V student. The first incident occurred when AAA’s mother, BBB, was away. Appellant entered the room where AAA and her siblings slept, removed her underwear, and had carnal knowledge of her. He threatened to kill her if she reported the act. He repeated the abuse several times, with the last incident occurring on May 27, 1997. AAA revealed the rapes to her grandmother, CCC, in May 1997 after being questioned about her distress. A medical examination revealed physical findings consistent with sexual intercourse.
Appellant pleaded not guilty and claimed the charges were fabricated by AAA’s paternal grandmother, who was allegedly angry about his marriage to BBB. The Regional Trial Court convicted appellant of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals affirmed the conviction. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the guilt of the appellant for the crimes of rape has been proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found AAA’s testimony to be credible, straightforward, and consistent. The defense of bare denial and alleged ill motive of the grandmother could not prevail over the positive and categorical identification by the victim. The Court emphasized that testimonies of child-victims of rape are given full weight and credit, as youth and immaturity generally make them incapable of fabricating tales of sexual abuse. The medical certificate, while noting a healed laceration, was consistent with AAA’s account of repeated abuse over time. The delay in reporting the incidents was sufficiently explained by the appellant’s threats against her life, which instilled reasonable fear.
Regarding the penalties, the Court modified the awards of damages in line with prevailing jurisprudence. For each count of rape, the appellant is sentenced to reclusion perpetua without eligibility for parole. He is ordered to pay the victim P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P50,000.00 as exemplary damages. The presence of the qualifying circumstance of relationship (stepfather-stepdaughter) and the victim being a minor warranted the imposition of exemplary damages.