Case Digest (G.R. No. 252214)
Facts:
In People of the Philippines vs. BBB (G.R. No. 252214, June 14, 2022), the accused-appellant, BBB, was indicted for two counts of rape for acts committed against his own daughter, AAA, in Pallocan West, Batangas. The first alleged incident took place in July 2013, when AAA was 13 years old (Crim. Case No. 18941), and the second on February 9, 2014, when she was 14 (Crim. Case No. 18942). BBB pleaded not guilty and proceeded to trial. AAA failed to appear and testify at hearings, prompting the court to order DNA sampling. The National Bureau of Investigation forensic chemist testified that DNA profiling conclusively established BBB as the biological father of AAA’s child, CCC, with 99.9999% probability. A social worker’s report explained AAA’s absence: she and her family returned to Romblon after being misinformed about DNA test fees. The Regional Trial Court (RTC), Branch I, Batangas City, acquitted BBB for the July 2013 charge (Nos. 18941) but convicted him for the February 201Case Digest (G.R. No. 252214)
Facts:
- Parties and Charges
- Accused-Appellant: BBB, biological father of the private offended party.
- Private Offended Party: AAA, minor daughter (13 years old in July 2013; 14 years old in February 2014).
- Two Informations filed:
- Crim. Case No. 18941 – Rape of 13-year-old AAA in July 2013.
- Crim. Case No. 18942 – Rape of 14-year-old AAA on February 9, 2014.
- Trial Proceedings and Evidence
- AAA did not testify at trial; prosecution proceeded on circumstantial evidence.
- DNA Test (NBI Forensic Chemist): paternity probability of 99.9999% showing BBB is father of AAA’s child CCC.
- Stipulated Testimonies:
- Aunt DDD’s affidavit on AAA’s pregnancy and paternity.
- PO Manalo’s role in arrest following complaint.
- Social Worker’s Case Study: AAA’s absence due to misinformation on DNA test cost; child CCC in grandmother’s care.
- Defense Case
- BBB’s flat denial of rape; claimed false accusation instigated by sister-in-law DDD.
- Denial of knowledge of AAA’s pregnancy and of DNA results’ veracity.
- Regional Trial Court (Branch I, Batangas City) Decision (April 16, 2018)
- Convicted BBB for rape in Crim. Case No. 18942 (February 2014 incident); acquitted in Crim. Case No. 18941 (July 2013 incident).
- Sentence: Reclusion perpetua; indemnity (P75,000), moral damages (P75,000), exemplary damages (P40,000); support for child CCC; credit for preventive detention.
- Court of Appeals Decision (November 11, 2019)
- Affirmed RTC decision with modifications: reclusion perpetua without parole; civil indemnity, moral and exemplary damages increased to P100,000 each.
- Held DNA conclusively established carnal knowledge; moral ascendancy of father substitutes force; date discrepancy immaterial.
Issues:
- Whether conviction may be based solely on circumstantial evidence in absence of victim’s testimony.
- Whether proof of force or intimidation is necessary in incestuous rape by a parent.
- Whether discrepancy between alleged dates of rape and child’s birth invalidates the prosecution.
- Whether defenses of denial and frame-up sufficiently counter the circumstantial evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)