Title
Supreme Court
People vs. XXX70149
Case
G.R. No. 270149
Decision Date
Oct 23, 2024
Accused-appellant XXX270149 convicted of qualified rape against his 6-year-old daughter, AF, by inserting his penis into her vagina. The ruling affirmed by CA and appealed by accused.

Case Digest (G.R. No. 270149)
Expanded Legal Reasoning Model

Facts:

  • Background
    • The accused-appellant XXX270149 was charged with violation of Article 266-A in relation to Article 266-B(1) of the Revised Penal Code, as amended, for the qualified rape of his biological daughter AAA270149, a six-year-old minor, on or about February 16, 2015.
    • The charge involved sexual intercourse committed by the accused against the victim without her consent and by virtue of the accused’s moral ascendancy and parental authority over the victim.
  • Procedural History
    • The case was initially filed on November 20, 2019, but was dismissed for lack of authority of the signing prosecutor.
    • The complaint was re-filed on December 12, 2019, and upon arraignment, the accused pleaded not guilty.
    • During pre-trial, the parties stipulated that the accused was the biological father of the minor victim.
    • Trial ensued where the victim, AAA270149, testified to the details of the sexual abuse.
  • Testimonies and Evidence
    • AAA270149 recounted that on the date in question, at the house of the accused’s friend Joey Amboyao, her father sexually abused her by first inserting a finger, then his penis, inside her vagina without her consent.
    • Melody Amboyao, a witness, testified that she observed the accused inside the bathroom with AAA270149, saw the victim’s underwear on the floor, and saw the accused with his pants pulled down with his penis inside the victim’s vagina.
    • Joey Amboyao testified that the accused fled the premises after the incident, leading to a physical altercation when Joey tried to apprehend him.
    • The accused denied the allegations, claiming he was climbing a coconut tree and that Joey assaulted him upon his descent.
  • Trial Court Findings
    • The Regional Trial Court (RTC) found the accused guilty of qualified rape, sentencing him to reclusion perpetua without eligibility for parole and ordering damages to the victim.
  • Court of Appeals Decision
    • The Court of Appeals (CA) affirmed the RTC’s decision, stating the prosecution successfully established guilt beyond reasonable doubt.
  • Supreme Court Appeal
    • The accused filed an appeal to the Supreme Court contesting the factual findings and credibility of the victim’s testimony and his denial.

Issues:

  • Whether the accused-appellant XXX270149 is guilty beyond reasonable doubt of qualified rape of a minor under Article 266-A in relation to Article 266-B(1) of the Revised Penal Code, as amended.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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