G.R. No. 262600 - People vs. AAA

AAA, accused-appellant, was charged in 24 Informations filed on January 12, 2016, of rape involving BBB, his 15-year-old stepdaughter.
The charges alleged that AAA, as stepfather, willfully, unlawfully, and feloniously had carnal knowledge of BBB against her will and without her consent by means of force, violence, and intimidation from December 1 to 24, 2015.
Each Information cited specific dates for the acts occurring around 4:00 a.m., when BBB's mother was away, with acts involving removal of clothing and forced sexual intercourse.

BBB testified that AAA sexually abused her repeatedly during the specified dates by forcing himself on her, threatening to kill her family if she resisted, and ordering silence.
BBB noted the broken lock on her room door, which was not repaired due to her family’s work commitments.
BBB’s sister EEE brought her to file a complaint after BBB could no longer endure the abuse.
Dr. Editha Martinez, medico-legal officer, found deep healed laceration at the 6 o'clock position of the hymen consistent with blunt penetrating trauma.
AAA denied the accusations, asserting he slept in a different room during the times alleged and that he lacked physical strength due to losing his left hand in an accident.
AAA claimed the accusations stemmed from family misunderstandings and maintained he had a good relationship with BBB.

The Regional Trial Court (RTC) convicted AAA of 7 counts of rape, acquitting him on other counts for insufficient evidence.
RTC noted the absence of legal marriage between AAA and BBB’s mother, thus not recognizing the stepfather relationship as a qualifying circumstance.
The Court of Appeals partially granted AAA's appeal, affirming conviction for 6 counts and acquitting one more count for insufficiency of evidence.

AAA appealed to the Supreme Court contesting his guilt in 6 counts of rape.
The Court examined legal qualifications for rape and qualified rape under Article 266-A and 266-B of the Revised Penal Code.
The Court considered the issue of moral ascendancy and its effect on the need to prove physical resistance or force.

Whether AAA is guilty beyond reasonable doubt of the six counts of rape.
Whether the accused’s relationship with BBB’s mother qualifies as a stepfather-stepdaughter relationship for qualified rape.
Whether physical resistance or evidence of physical force is necessary to prove the crime due to AAA’s moral ascendancy over BBB.
The credibility of BBB's testimony and sufficiency of evidence to convict AAA.