G.R. No. 260708 - People vs. ABC260708

ABC260708 (accused-appellant) was charged with qualified rape (Criminal Case No. 17006) and rape through sexual assault (Criminal Case No. 17007) committed against his minor daughter AAA260708.
The cases were filed before the Regional Trial Court (RTC) of Cagayan and subsequently appealed to the Court of Appeals (CA), then elevated to the Supreme Court.
The Informations alleged the offenses occurred on March 17, 2015.

AAA260708 testified that on March 15, 2015, ABC260708 called her to his room, removed her underwear, tied her to the bed, and had sexual intercourse with her by force. Afterwards, he inserted his penis into her mouth. He threatened to kill her if she reported the incident.
BBB260708, AAA260708’s older sister, witnessed parts of the aftermath by entering the locked house through an unfinished window and saw AAA260708 partially undressed and the accused wearing only briefs. She informed their aunt, and the incident was reported to authorities.
Medical examination on March 18, 2015, revealed fresh hymenal laceration within 24 hours of penetration.
ABC260708 denied the allegations, claiming he bathed his daughter on March 17, 2015 after harvesting corn, and that others whipped him based on false reports.

On July 10, 2019, the RTC convicted ABC260708 of qualified rape and rape through sexual assault.
The RTC admitted in evidence a photocopy of AAA260708’s birth certificate showing her age as 8 years old at the time, and confirmed filiation and parental authority.
Discrepancies in the exact dates of the incident were acknowledged but deemed immaterial given the credibility of witnesses.
Penalties imposed included reclusion perpetua for rape and imprisonment for sexual assault, along with civil indemnity, moral, and exemplary damages.

The CA affirmed the RTC's findings but modified the nomenclature to qualified statutory rape in Criminal Case No. 17006, sentencing ABC260708 to reclusion perpetua without parole eligibility.
In Criminal Case No. 17007, ABC260708 was convicted of sexual assault and sentenced to reclusion temporal with fines and damages awarded.
Interest on damages was imposed.

ABC260708 argued insufficiency of evidence and challenged AAA260708’s credibility.
No supplemental briefs were filed; all issues discussed before the CA were considered.

Whether the prosecution established the guilt of ABC260708 beyond reasonable doubt for qualified rape and rape through sexual assault.
Whether AAA260708’s testimony was credible and sufficient to convict ABC260708.
The proper taxonomic designation of the crime when elements of both statutory rape and qualified rape are present: Is "qualified statutory rape" a valid classification?
The proper penalties and damages to impose in light of the proper characterization of the crime.
The applicability and classification of aggravating circumstances related to statutory rape and qualified rape.