G.R. No. 96441 November 13, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HONORIO G. MABUNGA, accused-appellant.

FACTS

Accused-appellant Honorio G. Mabunga was charged with the rape of his daughter, Jenelyn Mabunga, on January 20, 1984, in Kalookan City. The information alleged he used force, intimidation, and a kitchen knife. The prosecution evidence established that on the said date, after sending his wife on an errand and his younger daughter out to play, appellant, armed with a knife, threatened to kill Jenelyn if she did not comply, forced her to undress, and had sexual intercourse with her in their one-room house. He threatened her not to tell anyone. Later that same day, he brought her to his guardhouse at the Airport Motel in Baclaran, where he raped her again that evening. Jenelyn stayed with him at the guardhouse, where she was repeatedly raped under threats of bodily harm. She eventually disclosed the abuse to an old woman and a relative, but no action was taken. On July 7, 1986, fearing appellant’s threat to impregnate her, she ran away and left a letter for her mother detailing the abuse. After her mother found the letter and confronted appellant (who initially admitted but later denied the rape), Jenelyn reported the crime to her uncle, a policeman. A complaint was filed, and a medico-legal examination confirmed an old healed deep laceration of her hymen and signs of repeated sexual intercourse. The defense presented evidence, including a certification of appellant’s assignments as a security guard, to allege he was on duty at a different location on January 20, 1984, and claimed the case was fabricated because his wife had a lover. The trial court found him guilty and sentenced him to reclusion perpetua.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape has been proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The Court found the testimony of the complainant, Jenelyn, to be credible, straightforward, and consistent. It held that in rape cases, the accused may be convicted solely on the credible testimony of the victim. The Court rejected the defense of alibi, noting it was not physically impossible for appellant to have been at the crime scene, and found the defense’s claim of fabrication unsubstantiated. The medico-legal findings corroborated the fact of sexual intercourse. The Court emphasized the gravity of incestuous rape and modified the trial court’s decision to award civil indemnity in the amount of P40,000.00 to the offended party. The amended judgment of the trial court was affirmed with this modification.