G.R. No. 258054 - People vs. XXX58054

On July 20, 2018, accused-appellant XXX258054 was charged with qualified rape under Article 266-A(1)(a) in relation to Article 266-B(1) of the Revised Penal Code, as amended by RA 8353.
The victim, AAA258054, was a 14-year-old minor and the biological daughter of XXX258054.
The incident occurred around May 24, 2018, at the residence within the jurisdiction of the court.

The accused, the victim's father, allegedly had carnal knowledge of AAA258054 by force, threat, intimidation, and use of a deadly weapon (knife), against her will.
The victim’s mother, BBB258054, sent her away to prevent her from testifying against her father.
Due to AAA258054’s unavailability as a witness, the prosecution relied on her Sinumpaang Salaysay and Sexual Abuse Protocol as evidence.

CCC258054, the accused's elder sister and the victim's aunt, testified that AAA258054 was crying and disclosed the abuse, including sexual molestation and penetration by the accused since she was 10 years old.
AAA258054’s Sinumpaang Salaysay detailed the abuse, including being forced to remove clothes and being sexually assaulted by her father.
PCINSP Reah Cornelio, medico-legal officer, conducted a medico-legal examination on May 28, 2018, and found deep healed hymenal lacerations consistent with penetration, supporting the victim’s claims.
Testimony of GGG258054, a cousin who witnessed the victim crying and narrated the incident.

XXX258054 denied the charges, claiming he was at the house of his eldest daughter YYY258054 at the time of the alleged incident.
Defense witnesses corroborated his alibi.

The Regional Trial Court found XXX258054 guilty beyond reasonable doubt and sentenced him to reclusion perpetua, awarding moral and exemplary damages of PHP 75,000 each.
The Court of Appeals affirmed the conviction, increasing damages to PHP 100,000 each and adding PHP 100,000 as civil indemnity.
The Court applied the doctrine of unavailable child and declared the Sinumpaang Salaysay and out-of-court statements as admissible under exceptions to the hearsay rule.

Whether or not the prosecution established the guilt of XXX258054 of qualified rape beyond reasonable doubt despite the victim’s unavailability to testify in person.
Whether the Sinumpaang Salaysay and hearsay testimonies of witnesses were admissible and credible under the unavailable child doctrine.
Whether crimes elements, including the qualifying circumstance of minority and relationship, were proven beyond reasonable doubt.
Whether the denial and alibi presented by the accused were credible and sufficient to acquit.
Whether the penalty and damages awarded were proper.