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PEOPLE v. PATRICIO TAGUIBUYA

FACTS:

The accused in this case was charged with two counts of rape and a violation of Republic Act No. 7610, committed against his own daughter, AAA, then a minor. The first instance of rape was alleged to have occurred in May 1998, when the accused forced AAA to have sexual intercourse while she was cleaning the rice fields. AAA was claimed to be a 15-year-old minor and the accused's own daughter during this incident. The second instance of rape took place on March 15, 2000, and was alleged to have occurred multiple times between May 1998 and March 2000. During this period, the accused allegedly raped AAA, who was then a 16-year-old minor and his own daughter. The charge of child abuse, which occurred between May 1998 and March 2000, involved the accused touching, caressing, and forcibly inserting his penis into AAA's private parts, constituting a violation of Republic Act No. 7610.

At his arraignment, the accused pleaded not guilty and denied the charges. He claimed that AAA fabricated the accusations in response to his and his wife's refusal to let her go with her boyfriend to Baguio, and the subsequent punishments he imposed on her. He argued that it was impossible for him to have committed the rapes in the areas where they were alleged to have taken place because these areas were visible to others. The accused's wife supported his denials.

After trial, the Regional Trial Court (RTC) found the accused guilty of two counts of qualified rape, but acquitted him of the violation of Republic Act No. 7610 due to the lack of an allegation that AAA was a child below eighteen years of age but over twelve years. The RTC sentenced the accused to death for both counts of rape and ordered him to pay civil indemnity and moral damages to AAA. The Court of Appeals (CA) affirmed the RTC's findings but reduced the penalty to reclusion perpetua for each count of rape.

The accused appealed the convictions, arguing that they were solely based on AAA's testimony. The Supreme Court affirmed the lower courts' decisions, stating that it could not contradict the factual findings and assessments of witnesses made by these courts.

ISSUES:

  1. Whether the accused should be acquitted due to lack of evidence.

  2. Whether the accused's convictions should be based solely on the testimony of the victim.

RULING:

  1. The accused's contention that he should be acquitted due to lack of evidence is unfounded. The Regional Trial Court (RTC) accorded credibility to the testimony of the victim, AAA, and found the accused guilty of two counts of qualified rape. The Court of Appeals (CA) affirmed the RTC's findings, including the credibility of AAA. As the reviewing tribunal, the CA's confirmation of the RTC's factual findings is entitled to great weight and respect. Therefore, the accused's motion for acquittal is denied.

  2. The accused argues that his convictions should not be based solely on the testimony of AAA. However, the Supreme Court affirms the RTC and CA's reliance on AAA's testimony. The trial court is in the best position to assess the credibility of witnesses, having directly observed their demeanor and demeanor during trial. It is well-settled that the testimony of a single witness, if credible and consistent, is sufficient to establish the guilt of the accused beyond reasonable doubt. In this case, AAA's testimony was found to be credible and consistent, and there were no inconsistencies or material contradictions that would cast doubt on her credibility. Therefore, the convictions of the accused based on AAA's testimony are upheld.

PRINCIPLES:

  • Credibility of witnesses is primarily a matter for the trial court to determine. As the original trier of fact, the trial court is in the best position to observe the demeanor and demeanor of witnesses. Its findings are entitled to great weight and respect, absent any showing of arbitrariness or palpable error.

  • The testimony of a single credible and consistent witness, if not contradictory or inherently improbable, is sufficient to establish the guilt of the accused beyond reasonable doubt.