In People of the Philippines vs. Benjamin Razonable, the Supreme Court affirmed the conviction of a father for the rape of his daughter, despite the information lacking a precise date for the commission of the crime. The Court emphasized that failure to raise objections about the information’s form during the trial constitutes a waiver of such defects. This ruling underscores the importance of timely raising procedural objections and highlights the court’s commitment to protecting victims of sexual abuse, especially within familial contexts, while ensuring that justice is served even when procedural technicalities are raised belatedly.

Silenced by Fear: When a Daughter’s Courage Unveils a Father’s Betrayal

The case revolves around Benjamin Razonable, who was found guilty of raping his daughter, Maria Fe Razonable, on three separate occasions in 1987. The Regional Trial Court of Camarines Norte sentenced him to three counts of reclusion perpetua and ordered him to pay P200,000 in moral damages. The informations charged Razonable with having carnal knowledge of his daughter against her will, using force and intimidation. The crimes were aggravated by the familial relationship and were committed in their dwelling.

Maria Fe testified that her father committed the acts in June 1987. She was only 12 years old at the time. She recounted how her father would enter her room at night, cover her mouth, and forcibly rape her. The appellant threatened her with death if she reported the incidents to anyone. It was not until February 1993 that Maria Fe disclosed the assaults to her sister, Ana Marie, due to her conscience and fear of further abuse. They then filed a complaint with the police, and a medical examination revealed incompletely healed hymenal lacerations.

Razonable denied the charges, claiming he was working at a bakery during the alleged incidents. He also alleged that his daughter filed the cases because he disciplined his children. Felix Razonable, the appellant’s brother, testified that Maria Fe and Ana Marie sought his help to withdraw the cases, but Maria Fe did not proceed out of fear of incarceration.

One of the key legal issues was whether the information was insufficient to support a conviction because it stated the offense occurred “sometime in the year 1987” without specifying the exact date. The appellant argued that this violated Section 6, Rule 110 of the Revised Rules of Court, which requires the approximate time of the offense to be stated. Section 11, Rule 110 further stipulates that the time of the commission must be alleged as near to the actual date as the information or complaint will permit.

The Supreme Court addressed the issue, stating that the failure to raise this objection during the trial constituted a waiver. The Court cited Section 11, Rule 110, and noted that the primary rationale for the rule is to inform the accused of the nature and cause of the accusation against him. The Court emphasized that procedural rules are in place to ensure the orderly administration of justice. It behooved the accused to raise the issue of a defective information via a motion to quash or a motion for a bill of particulars. “An accused who fails to take this seasonable step will be deemed to have waived the defect in said information.”

The Supreme Court highlighted that only specific defects in an information are not subject to waiver. These include cases where no offense is charged, a lack of jurisdiction, extinction of the offense or penalty, and double jeopardy. Objections regarding the form or substance of the information cannot be raised for the first time on appeal. In this case, Razonable failed to object to the indefiniteness of the allegation regarding the date of the offense either through a motion to quash or a motion for a bill of particulars.

Furthermore, the Court pointed out that the defense did not object to the prosecution’s evidence indicating the offense occurred in mid-June 1987. The appellant was able to provide an alibi for that specific time. Thus, the Court determined that Razonable could not claim he was unable to defend himself due to the vagueness of the information. The Court emphasized that it is the most natural reaction for victims of violence to remember their assailant. Also, the victim testified categorically that it was her father who raped her. Considering the Filipino culture’s reverence for elders, it is unlikely that a daughter would falsely accuse her own father of such a heinous crime.

Addressing the delay in filing the cases, the Court explained that such delays do not necessarily impair the victim’s credibility. Many rape victims prefer to remain silent rather than reveal their shame. In this case, Maria Fe was threatened with death if she reported the abuse. The fear instilled in her young mind by her father was sufficient to keep her silent. The Supreme Court referenced People vs. Melivo, 253 SCRA 347 (1996), in which the Court stated:

A rape victim’s actions are oftentimes overwhelmed by fear rather than by reason. It is this fear, springing from the initial rape, that the perpetrator hopes to build a climate of extreme psychological terror, which would, he hopes, numb his victim into silence and submissiveness. Incestuous rape magnifies this terror, because the perpetrator is a person normally expected to give solace and protection to the victim. Furthermore, in incest, access to the victim is guaranteed by the blood relationship, proximity magnifying the sense of helplessness and the degree of fear.

Similarly, in People v. Sevilla, G.R. No. 126199, December 8, 1999, the Court addressed a situation where the child victim did not report the abuse for eight years. The Court held that the victim’s young age and the traumatic experience could have caused confusion and bewilderment.

The fact that Maria Fe continued to live with Razonable was also addressed. The Court stated that she was a simple, naive 12-year-old child who was dependent on her father. It is not proper to judge the actions of children who have undergone traumatic experiences by the norms of behavior expected from mature persons. The appellant’s defense hinged on denial and alibi, which the Court deemed the weakest of all defenses, especially when the victim positively identified the accused. Affirmative testimony, like the victim’s, is stronger than a negative one. Razonable’s alibi was not credible, as he could not convincingly recall his work schedule five years after the incident. For an alibi to be considered valid, the accused must prove that he was so far away that he could not have been physically present at the crime scene.

The Court dismissed the appellant’s claim that his daughter and her siblings were motivated to file the charges because he disciplined them. It is unlikely that a daughter would concoct a story that could imprison her father for life. “It cannot be believed that appellant’s very own daughter would allow herself to be perverted if she was not truly motivated by a desire to seek retribution for the abominable violation committed against her by the father.”

The Court affirmed the trial court’s assessment of the victim’s credibility, finding her testimony sincere and candid. Considering that the acts were committed before Republic Act No. 7659 took effect, the trial court correctly imposed the penalty of reclusion perpetua for each case. The amount of P50,000 for each count of rape was awarded as moral damages, reducing the trial court’s original award to P150,000. Additionally, the victim was entitled to civil indemnity in the amount of P50,000 for each count of rape. The ruling clarifies the importance of raising objections to the form of an information promptly and underscores the court’s commitment to protecting victims of sexual abuse.

FAQs

What was the key issue in this case?	The key issue was whether the information was insufficient to support a judgment of conviction because it failed to state the precise date of the alleged commission of the offense. The appellant argued that the vague date violated his right to be informed of the charges against him.
Why did the Supreme Court uphold the conviction despite the vague date in the information?	The Supreme Court upheld the conviction because the appellant failed to raise this objection during the trial. The Court held that this failure constituted a waiver of the defect in the information, emphasizing the importance of raising procedural objections promptly.
What is the significance of Rule 110 of the Revised Rules of Court in this case?	Rule 110 requires that the information must state the approximate time of the commission of the offense. However, the Court clarified that if the accused does not object to the vagueness of the date during the trial, the defect is deemed waived.
What was the basis for the victim’s credibility despite the delay in reporting the crime?	The Court recognized that many rape victims delay reporting due to fear, shame, and threats from the perpetrator. In this case, the victim was threatened with death by her father if she reported the abuse, which justified her delay in disclosing the incidents.
How did the Court address the appellant’s alibi?	The Court dismissed the appellant’s alibi, noting that it is the weakest of all defenses and is especially unconvincing when the victim positively identifies the accused. The appellant’s inability to convincingly recall his work schedule five years after the incident further undermined his alibi.
What was the legal basis for the penalties imposed?	The Court imposed the penalty of reclusion perpetua for each count of rape, consistent with the law at the time the acts were committed (before the effectivity of Republic Act No. 7659). Additionally, the Court awarded moral damages and civil indemnity to the victim for each count of rape.
How did the Court view the familial relationship in this case?	The Court viewed the familial relationship as an aggravating circumstance, emphasizing that it is highly unlikely for a daughter to falsely accuse her own father of such a heinous crime. The betrayal of trust inherent in incestuous rape was a significant factor in the Court’s decision.
What are the practical implications of this ruling?	The ruling underscores the importance of timely raising procedural objections during trial and reinforces the protection of victims of sexual abuse, particularly in familial contexts. It also highlights the Court’s commitment to ensuring justice, even when procedural technicalities are raised belatedly.

This case underscores the judiciary’s commitment to protecting vulnerable individuals and ensuring that perpetrators of heinous crimes are brought to justice. The Supreme Court’s decision reinforces the importance of adhering to procedural rules while prioritizing the pursuit of justice and the protection of victims’ rights.

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 vs. Razonable, G.R. No. 128085-87, April 12, 2000