Title
People vs. XXX70317
Case
G.R. No. 270317
Decision Date
Oct 23, 2024
The Supreme Court affirmed the conviction of XXX270317 for acts of lasciviousness and multiple counts of rape against his minor daughters, increasing penalties and civil liabilities.

Case Digest (G.R. No. 270317)
Expanded Legal Reasoning Model

Facts:

  • Filing of Charges and Accusations
    • On March 10, 2015, two Informations were filed against accused-appellant XXX270317 for acts of lasciviousness and rape through sexual assault involving his daughters, aged 8 and 10.
    • Subsequent to these, six more cases were filed on June 15, 2015, charging six counts of sexual assault and statutory rape involving the same accused and his daughters.
  • Charges Described
    • Charges included acts of lasciviousness under Article 336 of the Revised Penal Code (RPC) in relation to RA 7610, six counts of rape through sexual assault under Article 266-A(2) of the RPC in relation to RA 7610, and statutory rape under Article 266-A(1)(d) of the RPC.
    • The victims, AAA270317 and BBB270317, were the minor daughters of the accused aged 9-10 during the incidents reported.
  • Trial Proceedings
    • AAA270317 testified to multiple instances of sexual abuse by her father starting in 2013 involving vaginal penetration and lascivious touching.
    • BBB270317 testified to repeated acts of sexual assault involving anal penetration starting in 2014 up to March 2015.
    • Another witness, CCC270317, a teacher, recounted how AAA270317 confided abuse in her and the report was forwarded to proper authorities.
    • The accused denied all allegations, claiming alibi and questioning the credibility of the victims.
  • Trial Court Decision
    • On October 1, 2019, the RTC found accused-appellant guilty beyond reasonable doubt on all charges.
    • The RTC awarded imprisonment sentences and ordered payment of moral and civil damages to the victims.
  • Appeal and Court of Appeals (CA) Ruling
    • The accused appealed to the CA contesting witness credibility and prosecution evidence sufficiency.
    • On September 27, 2022, the CA affirmed the conviction with modifications increasing penalties and civil damages and properly designating the crime of statutory rape as qualified rape.
  • Present Appeal
    • The accused filed a final appeal to the Supreme Court asserting the trial courts erred in their findings of guilt and witness credibility.

Issues:

  • Whether accused-appellant XXX270317 is guilty beyond reasonable doubt of:
    • Acts of lasciviousness under Article 336 of the Revised Penal Code in relation to RA 7610.
    • Six counts of sexual assault under Article 266-A(2) of the Revised Penal Code in relation to RA 7610.
    • Statutory rape under Article 266-A(1)(d) of the Revised Penal Code.
  • Whether the testimonies of the minor victims are credible and sufficient to convict.
  • The effect of prosecution’s non-presentation of medical certificates and the mother of the victims as witness.
  • Legality of penalties and civil indemnities imposed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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