G.R. No. 254878 - People vs. BBB254878

The accused-appellant, referred to as BBB254878, was charged with statutory rape under Republic Act No. 7610 through an Information dated April 17, 2013.
The Information accused him of having unlawful carnal knowledge with AAA, his 8-year-old niece, in September 2010 at Barangay xxxxx City, Eastern Samar.
The accused pleaded "not guilty" upon arraignment.

AAA, the victim, positively identified accused-appellant as her maternal uncle and recounts the incidents of sexual abuse starting September 2010.
She testified that the abuse included insertion of the accused's toe into her vagina during dinner, followed by repeated acts of sexual intercourse in a hut away from her grandfather's presence.
AAA stated the accused warned her not to disclose the abuse, threatening harm to her parents.
Dr. Ma. Theresa Tabungar, a Child Protection Specialist, performed physical and genital examinations, finding lacerations on AAA's hymen corroborating penetration.
CCC, AAA's mother, also testified confirming family relationships.

Accused denied the charges, claiming an alibi that he was at work during the times of the alleged incidents.

The RTC, in its May 7, 2018 decision, found the accused guilty beyond reasonable doubt of qualified statutory rape, sentencing him to reclusion perpetua without eligibility for parole and ordering payment of damages.
The Court of Appeals (CA) affirmed the conviction in its July 7, 2020 decision, modifying the damages awarded.
The CA reversed the qualification of the crime by relationship, stating the Information did not explicitly allege the accused was within the third civil degree of relationship, thus convicting only of statutory rape.

The Supreme Court took up the appeal, focusing on whether the accused was properly convicted of qualified statutory rape.
It evaluated the sufficiency of the Information regarding the familial relationship and the presented facts.

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of statutory rape.
Whether the crime is properly qualified by relationship, i.e., whether the relationship of "uncle-niece" was sufficiently alleged and proven to justify conviction for qualified statutory rape.
Whether the Information sufficiently informed the accused of the nature and cause of the accusation, particularly regarding the qualifying circumstance of relationship within the third civil degree.