Title
People vs. SPS. XXX62581 and YYY262581
Case
G.R. No. 262581
Decision Date
Aug 16, 2023
Spouses were convicted of raping their 14-year-old daughter. The CA affirmed the RTC's ruling, emphasizing the credibility of the victim's testimony.

Case Digest (G.R. No. 262581)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charges
    • Spouses XXX262581 and YYY262581 (accused-appellants) were charged with incestuous rape under Article 266-A, in relation to Article 266-B(1) of the Revised Penal Code, as amended by Republic Act No. 8353.
    • The victim was their 14-year-old daughter, AAA262581.
    • The charges arose from an incident on December 15, 2008, in Pangasinan, where the accused parents allegedly conspired for the father to have carnal knowledge of their daughter by force or intimidation.
  • Proceedings and Testimonies
    • The accused pleaded not guilty during arraignment.
    • The Regional Trial Court (RTC) conducted a joint trial of this case and other related rape cases involving the family.
    • The prosecution presented AAA262581, her sister BBB262581, and PO2 Joan Claire Espelita as witnesses.
    • AAA262581 testified in detail about the rape incident, narrating how her mother held her feet while her father raped her, causing her pain and fear. She disclosed the incident only in 2017 due to fear of her father and fatigue from ongoing abuse.
    • BBB262581 claimed she was forced by relatives to file rape charges against their father and denied any rape victimization.
    • PO2 Espelita testified about the investigation and interactions with the victims.
    • The defense witnesses, the accused spouses themselves, denied the accusations, presenting alibis and asserting the living conditions at home made the accusations improbable.
  • RTC Decision
    • On February 11, 2019, the RTC convicted XXX262581 and YYY262581 for rape based on the credible testimony of AAA262581 and the medico-legal report corroborating the injuries.
    • The defense's denial and alibi were rejected as weak and unconvincing.
    • The accused were ordered to pay civil indemnity, moral, and exemplary damages to the victim.
    • The accused were acquitted in other related cases filed by BBB262581 due to lack of evidence.
  • Appeal to Court of Appeals (CA)
    • The accused-appellants appealed, claiming inconsistencies in testimonies, lack of medico-legal expert testimony, delay in reporting, and vagueness of the date in the Information.
    • The CA, in its decision dated April 20, 2022, affirmed the RTC ruling, upholding AAA262581's credibility, the sufficiency of her testimony alone for conviction, and dismissing defense arguments.
  • Further Appeal to the Supreme Court
    • The People of the Philippines opposed the appeal, reiterating the strength of the prosecution case based on victim’s testimony and evidence.

Issues:

  • Whether the testimonies of AAA262581 and BBB262581 were conflicting and whether such conflicts affect the credibility of the victim27s testimony.
  • Whether the prosecution violated the accused27s right by failing to present the medico-legal expert who issued the medico-legal report.
  • Whether the delay in reporting the incident by AAA262581 undermines the credibility of her testimony.
  • Whether the Information27s failure to state the exact date of the offense prejudiced the accused.
  • Whether the defenses of denial and alibi by the accused-appellants were sufficient to overcome the prosecution evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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