G.R. No. 244835 - People vs. ABC

The case involves the People of the Philippines as the plaintiff-appellee and ABC as the accused-appellant.
ABC was charged in two separate Informations for crimes committed against his 9‑year‑old daughter.
The Crimes Charged:

Acts of Lasciviousness under Article 336 of the Revised Penal Code in connection with Section 5(b) of R.A. No. 7610.
Rape as defined under Article 266-A of the Revised Penal Code, as amended by R.A. No. 8353.

Occurred between January 13 and January 21, 2011, in Quezon City.
ABC, by means of force, threat, intimidation and by exercising moral ascendancy (as the father), allegedly committed repeated sexual abuse on his daughter (referred to as AAA) despite her being a minor and against her will.
Specific allegations include undressing the child forcibly, insertion of his penis, and even the appearance of urine during the act.
The crime of rape was charged with the qualifying circumstances due to the victim’s minority and the familial relationship.

Occurred between April and May 2011.
During this incident, ABC was similarly accused of committing sexual abuse on his daughter while she was in bed with other siblings, under dim lighting conditions.
The incident was observed indirectly by one of her brothers (DDD) who later testified regarding the shadows and movements in the room.
Although the act was described with reference to penetration by a foreign object, the trial court noted insufficient evidence to determine exactly what was inserted.

ABC entered separate pleas of “not guilty” when arraigned on October 9, 2014.
Pre-trial hearings were held on May 4, 2015, during which the prosecution presented key witnesses: AAA (the victim), along with BBB, CCC, DDD, and the medico-legal officer, Dr. Charyl Escaro.
During the joint trial on the merits, the prosecution established its case with the victim’s detailed testimony and corroborative evidence, including physical injuries and the findings of a medico-legal report.

Evidence of blunt penetrating trauma to the hymen in the form of deep, healed lacerations at specific positions.
Other physical signs such as healing ecchymoses and general indications of abuse.

AAA’s testimony described the incident as one of repeated abuse, noting that her father threatened her siblings not to disclose the matter.
A corroborative testimony was provided by DDD, the victim’s brother, who observed shadows and movements that supported the sequence of events.
The defense’s only witness was ABC himself, who denied all the charges and alleged that the crimes were fabricated due to personal animosity by his mother-in-law.

In Criminal Case No. R-QZN-14-07929-CR, ABC was found guilty beyond reasonable doubt of rape.
In Criminal Case No. R-QZN-14-07928-CR, due to insufficient evidence regarding the act of penetration, the court convicted ABC for Acts of Lasciviousness.
Penalties included reclusion perpetua for the rape conviction and an indeterminate sentence ranging from 6 months arresto mayor to 6 years prision correccional for the lasciviousness charge, along with monetary awards for civil indemnity, moral, and exemplary damages.

The Court of Appeals (CA) modified the nomenclature, penalty, and damage awards in Criminal Case No. R-QZN-14-07928-CR, reformulating the charge under the framework of R.A. No. 7610 and prescribing a reclusion temporal penalty.
ABC then elevated the case to the Supreme Court through a Notice of Appeal, insisting on his innocence and challenging both the sufficiency of evidence and the credibility of the prosecution witnesses.

Whether the prosecution was able to establish beyond reasonable doubt that ABC committed the crimes of rape and acts of lasciviousness despite the defendant’s denial.
Whether the evidence—particularly the detailed and corroborated testimony of AAA along with the medico-legal findings—was sufficient to prove the elements of the offenses.

Whether the inconsistencies or alleged contradictions in the testimonies of the prosecution witnesses (including AAA and DDD) should detract from their overall credibility.
Whether the trial court erred in giving full weight to such testimonies, especially given the vulnerabilities of a child victim.

The proper interpretation of Article 266‑A and 266‑B of the Revised Penal Code and its application in cases involving rape and qualified rape.
The alternative application of Section 5(b) of R.A. No. 7610 in cases of sexual abuse where the victim is below 12 or under 18 years of age.
Whether the modifications made by the Court of Appeals in terms of penalty and damage awards were proper in light of statutory provisions and aggravating circumstances.

Whether ABC’s reliance on denial—characterized as the weakest form of defense—was sufficient to overcome the strong evidentiary foundation established by the prosecution.

Whether the presence of the aggravating circumstance of familial relationship (i.e., the offender being the victim’s father) properly warranted the imposition of the harsher penalty as determined by the courts.