Facts:

The case involves Antonio Gaban y Fromento, who was accused of raping his 15-year-old daughter, Cristina, on three separate occasions in 1990. The family lived in a small house in Sitio Siwayan, Aroroy, Masbate, where Antonio was engaged in gold panning while his wife operated a sari-sari store. On several occasions, when his wife was away for marketing, Antonio would wake Cristina in the early morning hours, threaten her with a knife, and force her to submit to sexual intercourse. The first incident occurred in April 1990, followed by two more incidents in September and November of the same year. Cristina, fearing for her life and the safety of her family due to her father's threats, did not disclose the abuse until February 1991, when she confided in a relative. Tragically, Cristina's mother took her own life in September 1991, overwhelmed by the shame and humiliation stemming from the abuse.

After her mother’s death, Cristina decided to report the incidents to the police, accompanied by relatives. During the trial, the defense presented an alibi, claiming that Antonio was in Metro Manila during the times of the alleged rapes. The defense also argued that the charges were fabricated by relatives due to Antonio's reputation as a womanizer.

Legal Issues:

  1. Whether the testimonies of the complainant, Cristina, were credible and sufficient to establish the guilt of the accused.
  2. Whether the defense of alibi was sufficient to exonerate Antonio Gaban from the charges of rape.
  3. The appropriateness of the penalties and damages awarded to the victim.

Arguments:

Prosecution:

  • The prosecution argued that Cristina's testimony was candid, straightforward, and credible. They emphasized the psychological and emotional trauma she endured, which was compounded by her father's threats and the subsequent suicide of her mother.
  • The prosecution contended that the absence of physical resistance from Cristina did not negate the occurrence of rape, as intimidation and fear were significant factors in her submission.

Defense:

  • The defense claimed that Cristina did not resist or shout for help, which they argued undermined her credibility. They also maintained that Antonio was in Metro Manila during the alleged incidents, thus providing an alibi.
  • The defense suggested that the charges were fabricated by relatives of his wife, motivated by personal animosity due to Antonio's alleged infidelity.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Antonio Gaban guilty of rape on three counts. The court held that the testimony of Cristina was credible and compelling, noting that it is difficult to believe that a young girl would fabricate such serious allegations against her father. The court emphasized that the psychological impact of the threats made by Antonio, coupled with the familial relationship, significantly influenced Cristina's ability to resist or seek help during the assaults.

The court also ruled that the defense of alibi was insufficient to counter the positive identification of the accused by the complainant. The court found that the alibi was self-serving and lacked corroborative evidence. Furthermore, the court noted that Antonio's letter to Cristina, in which he expressed remorse and sought forgiveness, served as an implicit admission of guilt.

In terms of penalties, the court upheld the trial court's sentence of reclusion perpetua for each count of rape. However, it modified the civil indemnity awarded to Cristina, increasing it to P150,000 for moral damages and adding P75,000 for exemplary damages, totaling P225,000.

Significant Legal Principles Established:

  1. The credibility of a rape victim's testimony, especially when it involves a close relative, is given significant weight by the courts, particularly when the victim's account is consistent and detailed.
  2. The absence of physical resistance does not negate the occurrence of rape if the victim was subjected to threats and intimidation.
  3. Alibi defenses must be supported by credible evidence; mere assertions without corroboration are insufficient to exonerate an accused in the face of strong evidence from the prosecution.