## FACTS:

The accused-appellant, Leo Echegaray, was charged with the crime of rape. The complainant, Rodessa Echegaray, is his ten-year-old daughter. The incident occurred sometime in April 1994 when Rodessa was left at home with her three younger brothers while her mother was out. The accused-appellant ordered the brothers to leave the house and then dragged Rodessa inside a room. He removed her panty and made her lie on the floor, where he forcefully inserted his penis into her, causing her intense pain. He continued to sexually assault her multiple times, threatening to kill her mother if she told anyone. Eventually, Rodessa informed her grandmother, who then told her mother about the assaults. Rodessa and her mother reported the incidents to the Barangay Captain and the police station. Rodessa underwent a medical examination, which confirmed the presence of laceration of her hymen, indicating non-virginity. The accused-appellant denied the accusations, claiming that they were motivated by the greed of Rodessa's grandmother over a piece of property given to him by her paramour.

In this case, the accused-appellant was charged with the crime of rape allegedly committed against the complainant, Rodessa. The complainant initially filed a complaint for attempted homicide against the accused, but it was later substituted with the crime of rape at the instance of her mother. The complainant executed an affidavit of desistance, but when her mother found out about it, she placed the complainant's daughter under the custody of the Barangay Captain. The complainant stated that her complaint against the accused was for attempted homicide because her husband poured alcohol on her body and attempted to burn her. She also testified that the property where the accused and her mother lived was co-owned by the accused and Conrado Alfonso, who is the father of the complainant. The accused, on the other hand, testified that the complainant's grandmother had a strong motive to implicate him in the crime of rape because she wanted to become the sole owner of a property awarded to her live-in partner. He denied committing the crime and claimed that he treated the complainant as his own daughter. The accused's testimony was further supported by witnesses who testified about the complainant's sexual behavior and exposure to explicit materials. The trial court found the accused guilty of rape, disregarding his defense of alibi and the argument that his penis size could not have caused the alleged injuries. The accused now seeks the reversal of the court's verdict by raising several alleged errors.

ISSUES

1. Whether the rape charge against the accused-appellant, Leo Echegaray, was valid and substantial enough to warrant his conviction.

2. Whether the circumstances and evidence presented affirm the guilt of the accused-appellant for the crime of rape against his ten-year-old daughter, Rodessa Echegaray.

3. Whether the death penalty, as imposed by the trial court, is appropriate for the accused-appellant under the circumstances of the case.

RULING

1. The Supreme Court found the rape charge against Leo Echegaray valid and substantial. The Court dismissed accusations of conspiracy and fabrication by Echegaray’s defense, emphasizing the improbability that a grandmother would prompt her granddaughter to falsely accuse her father of rape merely over a dispute regarding property.

2. The Court ruled that the victim’s straightforward, consistent, and convincing testimony, despite minor inconsistencies highlighted by the defense, was sufficient to affirm the accused-appellant’s guilt. The defense of alibi was considered weak and uncorroborated, thus did not outweigh the clear testimonial evidence.

3. The imposition of the death penalty was affirmed by the Supreme Court. The relationship dynamic between the victim and the accused-appellant (father/stepfather), as well as aggravating circumstances (incest), solidified the Court’s decision to uphold the trial court’s sentence.

PRINCIPLES

1. The testimony of a rape victim is credible when she appears to have no motive to falsify her account.

2. Minor inconsistencies in a victim’s testimony do not automatically discredit their overall credibility.

3. The defense of alibi is inherently weak and must be substantiated convincingly to be deemed credible.

4. The presence of a common-law relationship between the accused and the victim’s parent aggravates the crime where the accused holds a position of authority or trust relative to the victim.

5. The reimposition of the death penalty for heinous crimes under certain aggravating circumstances is reiterated, emphasizing the serious nature of crimes such as rape, especially when committed against minors by their guardians or parents.