FACTS:
Jenelito Escober was charged with two counts of statutory rape based on complaints filed by his daughter, Ma. Cristina Escober. On the evening of December 19, 1993, Jenelito arrived home drunk and asked Ma. Cristina to turn off the light and transfer to his bed. He then removed her panty, kissed her, and proceeded to rape her. Ma. Cristina resisted but was overpowered by her father's physical strength. After the incident, Jenelito left. The next morning, Ma. Cristina felt pain in her vagina but did not disclose the incident to her mother due to fear. On the evening of December 22, 1993, Jenelito arrived home drunk again and forced himself on Ma. Cristina for the second time. She again resisted but was unable to stop her father. She felt pain in her vagina when she urinated but chose to remain silent. The defense argued that Ma. Cristina's visit to her father in jail and her letter exculpating him, as well as the absence of disclosure due to fear of her mother's reaction, and disputes within the family negated the allegations. It was also claimed that on the nights of the alleged incidents, Jenelito was in the house of Claro Estrera repairing a television set. Claro Estrera corroborated Jenelito's alibi. However, the trial court considered these reasons weak and flimsy.
ISSUES:
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Whether the accused should be convicted of the crime of statutory rape.
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Whether the reasons given by the defense are sufficient to explain the filing of the rape cases against the accused.
RULING:
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The accused should be convicted of the crime of statutory rape. The court found the testimony of the victim credible and consistent with the elements of statutory rape. The accused, the victim's father, forcibly had sexual intercourse with the victim, who was only eleven years old at the time of the incidents. The court rejected the defense's argument that the victim's testimony should not be believed due to inconsistencies in her statements and the presence of certain circumstances showing the innocence of the accused.
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The reasons given by the defense are not sufficient to explain the filing of the rape cases against the accused. The court found that the defense's reasons were weak and flimsy, and were not enough to justify the victim or her mother breaking the bond between the child and her father, and between the wife and her husband. The court did not find any evidence to support the defense's claim that the charges were filed as a result of marital discord or to teach the accused a lesson.
PRINCIPLES:
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Credibility of the victim's testimony in cases of sexual abuse
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Elements of statutory rape
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Weakness of defenses based on weak and flimsy reasons or motives for filing rape cases