In the case of People of the Philippines v. Alejandro Guntang, the Supreme Court affirmed the conviction of a father for the incestuous rape of his 15-year-old daughter, emphasizing the reliability of the victim’s testimony and the severity of the crime. The Court underscored that familial relations cannot be a shield for abuse and that the victim’s account, when consistent and credible, holds significant weight. This decision reinforces the importance of protecting vulnerable individuals within family structures and ensuring justice for victims of incestuous crimes.

When Trust is Betrayed: Can a Father’s Alibi Overcome His Daughter’s Testimony of Incestuous Rape?

Alejandro Guntang was charged with five counts of raping his 15-year-old daughter, Lizabeth. The Regional Trial Court of Urdaneta, Pangasinan found him guilty and sentenced him to death for each count. Guntang appealed, claiming innocence and presenting an alibi, while also questioning the credibility of his daughter’s testimony. The central legal question before the Supreme Court was whether the trial court erred in relying on Lizabeth’s testimony and whether Guntang’s alibi was sufficient to overturn the conviction.

The Supreme Court meticulously reviewed the trial records, paying particular attention to Lizabeth’s testimony. The Court found no significant flaws in her account, noting its consistency and the emotional distress she exhibited while testifying. The testimony of Lizabeth Guntang was clear and consistent. As an example of the testimony:

“He held my two hands and then forced his organ to be placed in my organ, sir.”

Building on this principle, the Court addressed the defense’s argument that the rapes could not have occurred without other family members being aware. The Court referenced established jurisprudence that copulation can occur even in the presence of others, especially considering the cramped living conditions and potential for family members to be asleep or desensitized to such occurrences. Further, the court notes that the lack of privacy does not negate the possibility of the crime. The Court emphasized that the psychological dynamics within a family can allow such abuse to occur without immediate detection.

The Court also dismissed Guntang’s claim that Lizabeth and her grandmother harbored ill feelings towards him, suggesting a motive for false accusations. The court determined that these imputed motives were too shallow to undermine the credibility of the victim’s testimony. It is highly improbable for a young girl, with no prior history of sexual perversity, to fabricate such a story against her own father, risking his liberty and bringing shame upon herself and her family. The Court acknowledged that Lizabeth’s initial silence could be attributed to her age, the accused’s authority, and his threats against her life. The court further stated:

“The initial silence of Lizabeth could be attributed to her age, the moral ascendancy of the accused and his threats against her life. Lizabeth was barely 15 years old when she was first raped by the accused. Procrastination by the victim in rape cases had seldom been taken to be an indication of a fabricated charge.”

Guntang’s defense of alibi was also rejected by the Court. To be credible, an alibi must not only prove the accused’s presence at another location but also demonstrate the physical impossibility of being at the crime scene at the time of the offense. The evidence presented by Guntang failed to meet this standard, rendering his alibi unsatisfactory against the positive identification and testimony of the victim.

The Court referenced the Revised Penal Code’s Article 335, as amended by Republic Act 7659, which prescribes reclusion perpetua for simple rape. However, because the victim was under eighteen years of age and the offender was her parent, the penalty was increased to death. The Court presented Lizabeth’s testimony and birth certificate as evidence of her age, along with Guntang’s admission of being her legitimate father.

The Court also addressed the monetary liability of the accused-appellant. Citing prevailing jurisprudence, the Court increased the civil indemnity to P75,000.00 for each count of rape, in addition to P50,000.00 in moral damages. The Supreme Court has ruled that the civil indemnity be increased when rape is qualified by circumstances authorizing the death penalty. The court stated:

“As to the monetary liability of accused-appellant, the amount of P75,000.00 as civil indemnity should be awarded to the complainant for each count of rape. The Supreme Court has ruled that if the crime of rape is committed or effectively qualified by any of the circumstances under which the death penalty is authorized by law, the indemnity for the victim shall be increased to P75,000.00.”

The court also granted P20,000.00 in exemplary damages, recognizing the trauma and suffering endured by the victim.

The Court emphasized the victim’s trauma, stating that the mental, physical, and psychological sufferings of a rape victim are obvious and need no further recital at trial. The Court acknowledged the victim’s agony, thus, awarding the payment for damages.

In summary, the Supreme Court affirmed the lower court’s decision, finding Guntang guilty beyond reasonable doubt of five counts of rape. The decision underscored the importance of protecting vulnerable individuals within family structures and ensuring justice for victims of incestuous crimes, the Supreme Court increased the civil indemnity to P75,000.00 for each count of rape, in addition to P50,000.00 in moral damages, and P20,000.00 in exemplary damages.

FAQs

What was the key issue in this case?	The key issue was whether the trial court correctly relied on the victim’s testimony to convict the accused of incestuous rape, and whether the accused’s alibi was sufficient to overturn the conviction.
What was the age of the victim at the time of the rapes?	The victim, Lizabeth Guntang, was 15 years old at the time of the first rape incident and still a minor during the subsequent incidents, as confirmed by her birth certificate and testimony.
What was the accused’s defense?	The accused, Alejandro Guntang, claimed innocence and presented an alibi, arguing that he was at the rice field during the times the rapes allegedly occurred.
Why did the Court reject the accused’s alibi?	The Court rejected the alibi because the accused failed to prove that it was physically impossible for him to be at the crime scene at the time of the offenses.
What was the basis for the Court’s decision to uphold the conviction?	The Court upheld the conviction based on the consistent and credible testimony of the victim, which was found to be free of significant flaws, and supported by medical evidence indicating a ruptured hymen with lacerations.
What were the monetary liabilities imposed on the accused?	The accused was ordered to pay the victim P75,000.00 as civil indemnity, P50,000.00 as moral damages, and P20,000.00 as exemplary damages for each count of rape.
How did the Court address the issue of the victim’s initial silence?	The Court explained that the victim’s initial silence could be attributed to her age, the accused’s moral ascendancy, and his threats against her life, and that delay in reporting rape is not necessarily indicative of a fabricated charge.
What specific law was applied in this case?	The case was decided under Article 335 of the Revised Penal Code, as amended by Republic Act 7659, which prescribes the penalty for rape and increases it when the victim is under eighteen years of age and the offender is a parent.
What did the medical examination of the victim reveal?	The medical examination revealed a ruptured hymen with lacerations at 1, 5, 7, and 9 o’clock positions, which supported the victim’s claim of sexual assault.

This case underscores the critical importance of protecting vulnerable individuals within familial relationships. The ruling serves as a reminder that familial bonds should not shield perpetrators of abuse from justice. It also highlights the significance of consistent and credible testimony from victims, even in the face of an alibi defense.

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 v. Guntang, G.R. Nos. 135234-38, March 08, 2001