Case Digest (G.R. No. 268654)
Facts:
In Criminal Case Nos. 7465, 7466, and 7467, the accused-appellant, XXX, was charged with three counts of qualified rape committed against his daughter, AAA, who was 9 to 11 years old at the time of the incidents occurring in 2013 and 2014. The crimes happened at midnight on separate dates—October 2013, December 29, 2013, and November 23, 2014—within the jurisdiction of the Regional Trial Court (RTC). The victim, AAA, testified that her father forcibly engaged in sexual intercourse with her, despite her resistance and will. Medical examination corroborated the presence of hymenal lacerations consistent with rape. The trial court found the testimony of AAA credible and convicted XXX of three counts of qualified rape, sentencing him to reclusion perpetua and ordering him to pay civil, moral, and exemplary damages, each amounting to PHP 100,000. The Court of Appeals (CA) affirmed the conviction with modification, renaming the crime as qualified statutory rape, sentencing XXX to rec
Case Digest (G.R. No. 268654)
Facts:
- Charges and Parties
- XXX, the accused-appellant, was charged in three separate Informations with three counts of qualified rape allegedly committed against his 11-year-old daughter, AAA.
- The incidents occurred on October 2013, December 29, 2013, and November 23, 2014.
- The accused pleaded not guilty to all charges.
- Details of the Crimes
- Each charge accused XXX of having carnal knowledge of AAA by force, intimidation, and moral ascendancy, given the father-daughter relationship.
- The victim was a minor between 9 to 11 years old during the incidents.
- Procedural Background
- Pretrial and trial on the merit ensued, with the victim being the primary witness for prosecution.
- AAA testified to being raped by her father on three occasions, describing in detail the acts including penetration, resistance, and pain.
- AAA’s mother, BBB, discovered the abuse after AAA’s confession and assisted in filing complaints.
- Medical Evidence
- Dr. Arnel Tuanqui Borja examined AAA and issued a Medico-Legal Certificate that noted a "non-intact hymen" and healed hymenal laceration at 7 o’clock position.
- Defense’s Position
- XXX denied the allegations, claiming he was engaged in benign activities such as feeding AAA.
- He asserted that on two of the dates, AAA and siblings were sleeping beside their grandfather, making the commission of the acts impossible.
- Trial Court's Findings
- The Regional Trial Court found XXX guilty beyond reasonable doubt of the three counts of qualified rape.
- The RTC gave more weight to AAA’s testimony over the denial of the accused.
- Court of Appeals Decision
- The CA affirmed with modification that XXX committed qualified statutory rape due to the victim being below twelve years old.
- Included in the sentencing was reclusion perpetua without eligibility for parole and various damages.
- Appeal to the Supreme Court
- XXX appealed the CA decision.
Issues:
- Whether the Court of Appeals erred in convicting XXX of three counts of qualified statutory rape in Criminal Case Nos. 7465, 7466, and 7467.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)