Case Digest (G.R. No. 262581)
Facts:
People of the Philippines v. Sps. XXX262581 and YYY262581, G.R. No. 262581, August 16, 2023, the Supreme Court Second Division, Lopez, M., J., writing for the Court.The accused-appellants are spouses XXX262581 and YYY262581; the offended party is their daughter, identified in the record as AAA262581. The spouses were charged by Information with incestuous rape under Article 266‑A of the Revised Penal Code, in relation to Article 266‑B as amended by Republic Act No. 8353, alleging that in 2008 the parents, by means of force or intimidation, conspired and had sexual intercourse with their then‑14‑year‑old daughter. Other rape complaints by BBB262581 against XXX262581 were raffled to another branch.
Upon arraignment the spouses pleaded not guilty. During pre‑trial the parties stipulated to the accuseds’ parentage of AAA262581, AAA262581’s minority at the time of the alleged incident, and the authenticity and due execution of AAA262581’s medico‑legal report. The Regional Trial Court (RTC) joined the trial of the case filed by AAA262581 with the rape cases filed by her sister BBB262581.
At trial the prosecution presented AAA262581, BBB262581, and Police Officer II Joan Claire Espelita. AAA262581 testified that on December 15, 2008 her mother woke her, instructed her to lie beside her father, held her feet while her father removed her shorts and panty, and then the father inserted his penis into her vagina for about five minutes; she said she did not report the incident earlier because she was afraid. BBB262581 testified that she accompanied AAA262581 to the police in 2017 but denied being raped herself and later claimed she was coerced to file charges. PO2 Espelita corroborated aspects of the May 29, 2017 police report and the sisters’ identification of their parents.
The defense presented both spouses who denied the allegations, claimed crowded sleeping arrangements that made the charged acts unlikely, and asserted alibi and denial defenses. In a Decision dated February 11, 2019, the RTC convicted both spouses in Criminal Case No. L‑11634, finding AAA262581’s testimony categorical and corroborated by a medico‑legal report noting an “old scar” on the hymen; the RTC imposed reclusion perpetua and awarded PHP 100,000 each for civil indemnity, moral and exemplary damages, and acquitted XXX262581 in the other cases (Criminal Cases L‑11648 to L‑11671). The spouses appealed to the Court of Appeals (CA).
In a Decision dated April 20, 2022 (CA‑G.R. CR‑HC No. 13030), the Court of Appeals affirmed the RTC conviction. The CA found AAA262581’s testimony credible and straightforward, held that the medico‑legal certificate was unnecessary when the victim’s testimony is cred...(Subscriber-Only)
Issues:
- Did the trial court and the Court of Appeals commit reversible error in accepting AAA262581’s testimony as credible and convicting the spouses on that testimony?
- Was the failure to present the medico‑legal examiner fatal to the prosecution’s case?
- Did AAA262581’s delay in reporting the rape undermine her credibility and the prosecution’s case?
- Was the Information defective for alleging only that the rape occurred “sometime in the year 2008”?
- Were the accuseds’ denials and alibi s...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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