G.R. No. 266706 - People vs. ZZZ

Accused-appellant ZZZ was charged before the Regional Trial Court (RTC) of Dagupan City with multiple offenses:

Three counts of Rape under Article 266-A, paragraph 1(a) of the Revised Penal Code (RPC).
One count of Rape by Sexual Assault under Article 266-A, paragraph 2 of the RPC.
One count of Acts of Lasciviousness under Republic Act No. 7610.
Three counts of Child Abuse under Republic Act No. 7610.
One count of Violation of Section 5(a) of Republic Act No. 9262 (Anti-Violence Against Women and Children Act).

Complainants AAA, BBB, CCC, and DDD are minors and children of ZZZ with his wife EEE.
AAA is the principal complainant in the rape cases, starting from age 9.

Initial sexual abuse of AAA started in April 2009 when she was 9 years old; accused forced her to sit on his abdomen and inserted his finger into her vagina.
In April 2011, ZZZ raped AAA, forcibly inserting his penis into her vagina and mouth.
Between October and November 2012, ZZZ forced AAA to perform acts such as kissing him, touching his penis, and raped her again.
In August 2015, ZZZ attempted further sexual abuse but failed due to resistance and illness.
On September 19, 2017, ZZZ physically assaulted AAA, her siblings BBB, CCC, DDD, and wife EEE at their grandparents' house, inflicting various injuries.

Victims AAA, BBB, CCC, DDD, and EEE testified regarding the repeated sexual and physical abuse.
Dr. Patrick Lawrence Manaois examined the victims and certified various injuries consistent with abuse, including healed deep hymenal lacerations on AAA.
Documentary evidence included medical certificates, birth and marriage certificates, and affidavits.

ZZZ denied all rape allegations, admitted to being strict but claimed that discipline was necessary.
ZZZ's sisters XXX and YYY testified that AAA never mentioned abuse, and physical arrangements made rape physically unlikely.
ZZZ claimed family discord stemmed from EEE’s parents seeking custody.

The RTC convicted ZZZ of two counts of rape, one count of rape by sexual assault, and four counts of slight physical injuries.
ZZZ was acquitted of acts of lasciviousness and violation of RA 9262 due to reasonable doubt.

The Court of Appeals (CA) affirmed the RTC's ruling with modifications to penalties and damages.
The CA increased penalties for qualified rape and ordered higher damages.
CA convicted ZZZ of violation of RA 9262, reversing the RTC acquittal without sufficient discussion.

ZZZ appealed to the Supreme Court.
The Court partially granted the appeal, confirming rape and slight physical injuries convictions but reversed the CA's reversal regarding RA 9262 due to double jeopardy.

Whether the Court of Appeals correctly affirmed the RTC’s conviction of ZZZ for multiple counts of rape, slight physical injuries, and violation of RA 9262.
Whether the testimony of the principal witness AAA is credible.
Whether the delay in reporting the sexual abuse affects the credibility of the victim and the sufficiency of the prosecution’s evidence.
Whether the alleged acts of physical injuries committed lacked criminal intent.
Whether the CA's reversal of the RTC's acquittal on the RA 9262 citation violated the constitutional protection against double jeopardy.