Supreme Court upholds conviction of man who raped 2 daughters

MANILA, Philippines - The Supreme Court (SC) has affirmed the conviction of a man who raped his two daughters, both minors, in Camarines Sur in 2002.

In a decision penned by Associate Justice Mariano del Castillo, the SC First Division upheld the ruling handed down by the regional trial court (RTC) of Calabanga, Camarines Sur that found Efren Alfonso guilty of statutory rape and rape by sexual assault.

The SC said the RTC was correct in sentencing Alfonso to life imprisonment without eligibility for parole for raping in 2002 his then five-year-old daughter and an additional jail term of up to 17 years for sexual assault on his other daughter, who was then only three years old.

Chief Justice Renato Corona and Associate Justices Presbitero Velasco Jr., Teresita Leonardo-De Castro and Jose Perez concurred with the ruling.

The RTC, in its decision on May 25, 2006, gave credence to the testimony of Alfonso’s wife and the results of the physical examination conducted on his two daughters.

The trial court found it unusual that Alfonso did nothing at all upon learning of the sexual molestations suffered by his daughters that were allegedly committed by one of his sons.

Worse, after learning over the radio that he was accused of raping his daughters, he went into hiding until his arrest two years later.

The court also found the victims as competent witnesses despite their young age. After carefully observing their manner of testifying, it was satisfied that they could “perceive, remember, communicate, distinguish truth from falsehood or appreciate the duty to tell the truth in court.”

Alfonso was also ordered to pay his two daughters P180,000 and P90,000 as civil indemnity, moral damages and exemplary damages.

In its ruling, the SC said, “It is unthinkable that a child of tender years placed under rigid cross-examination would not loosen up or break down and reveal the details of such a traumatic experience including pinpointing the actual perpetrator of the crime.”

“It is believed that such traumatic experiences are deeply engraved in the memory of the victim and will certainly come to the surface once the victim is confronted and cross-examined especially when the victim is an innocent and naive child. Their natural innocence and naiveté will prevent them from sustaining a lie,” it added.

The SC also found no basis to Alfonso’s claim that his wife coached their daughters to testify falsely against him, saying the victims were consistent in pointing out that it was their father who committed the sexual acts against them.

Alfonso’s wife testified during the trial that she saw her two daughters crying and in a state of shock on April 8, 2002 when she and her two sons returned home from a two-day visit to a quack doctor in Magarao, Camarines Sur.

She initially brought her daughters to the quack doctor but was prevailed upon to bring them to a hospital for medical examination. Upon her prodding, the two confessed that they were sexually abused by their father.

During the trial, the prosecution also presented Dr. Augusto Quilon Jr., a resident physician at the Bicol Medical Center, who testified on the results of the medical examinations conducted on Alfonso’s daughters.

The two young victims also took the witness stand. In their respective testimonies, they confirmed that they were sexually abused by their father on April 7, 2002.

For his defense, Alfonso presented himself as the lone witness and claimed that he was working at a sugarcane plantation located about two kilometers away from their house when the sexual assaults happened.