G.R. No. 200242 - Corona vs. Senate of the Philippines

The case involves the People of the Philippines as plaintiff-appellee and BBB as accused-appellant.
BBB, a soldier in the Philippine Army and live-in partner of DDD, is charged with multiple offenses involving violence and rape.
The victims include DDD’s two minor daughters, AAA and CCC, with both incidents occurring when the victims were only 13 years old.

Criminal Case No. 12493 – Accused committed violence against his common-law wife DDD and her children AAA and CCC by inflicting mental or emotional anguish, in violation of Section 5(i) of Republic Act No. 9262.
Criminal Case No. 12605 – Accused allegedly raped his stepdaughter AAA on the early morning of December 10, 1999, through the use of force, threat, and intimidation (violating Article 266-A of the Revised Penal Code in relation to Republic Act No. 7610).
Criminal Case No. 12606 – Accused allegedly raped his stepdaughter CCC on the night of March 30, 2004, similarly by force and intimidation under the same legal provisions as the previous charge.

On December 10, 1999, BBB entered the room where AAA had just arrived home, undressed her, removed her undergarment, and forcibly inserted his penis into her vagina.
He threatened the minor with a gun, warning her that he would kill her family members if she told anyone.

On March 30, 2004, while CCC was alone in the house during a wake vigil, BBB followed her after she retreated to her room during a card game and forcibly raped her.
He threatened CCC to remain silent, indicating that any disclosure would result in lethal consequences.

A month after the incidents, on April 25, 2004, both sisters confided in their mother, which led to the filing of a report at the National Bureau of Investigation.
A municipal health officer corroborated the testimonies by revealing that both minors exhibited “old lacerations in their hymens” and were in non-virginal states.
DDD, the victims’ mother, also testified, recounting her shock and the emotional trauma upon learning of the abuse.

For Criminal Case No. 12493, he was found guilty of violating Section 5(i) of R.A. 9262 and received an indeterminate sentence ranging from six (6) years (prision correccional) to ten (10) years and one (1) day (prision mayor), along with a fine of ₱200,000.00 and mandatory psychological counselling.
For Criminal Cases Nos. 12605 and 12606 (qualified rape), BBB was sentenced to reclusion perpetua for each count and ordered to pay specified amounts as civil indemnity, moral damages, and exemplary damages.

The sentencing also provided that the time the accused had been detained since May 4, 2004, would be credited in his total sentence.

The report by DDD was motivated by personal motives, claiming she intended to rid herself of him.
His alibi—that he was in Jolo, Sulu on December 10, 1999, and in a business meeting with witness Bornia on March 30, 2004—should have merit.

The Court of Appeals, while affirming the convictions, modified the penalties and award of damages in light of precedents such as People v. Jugueta and People v. Jugueta.
Both parties eventually refrained from filing supplemental briefs following the Court of Appeals’ resolution on the factual and legal issues presented.

The Supreme Court reviewed the case on appeal, focusing on whether the Court of Appeals erred in affirming BBB’s conviction.
It held that the clear, candid, and consistent testimonies of the minor victims prevailed over the unsubstantiated alibi and denial presented by BBB.
Medical evidence and witness demeanor, along with the corroborative narrative, confirmed the commission of the crimes as charged.
Consequently, the Supreme Court dismissed BBB’s appeal, thereby affirming the decisions of the lower courts.

Whether the coherent, candid, and straightforward testimonies of the minor victims could overcome BBB’s defense based on alibi and denial.
Whether the uncontradicted narrative by the victims, together with medical and other corroborative evidence, was enough to establish the crime beyond reasonable doubt.

Whether the evidence presented—including testimonies, medical findings, and the demeanor of the witnesses—was capable of supporting the conviction for qualified rape and violation of Section 5(i) of R.A. 9262.
Whether BBB’s assertions regarding his presence in Jolo, Sulu and at a business meeting could be substantiated or effectively rebutted by the established facts.

Whether the modifications in penalty and the adjustments in award of damages made by the Court of Appeals in light of existing jurisprudence were proper and justifiable.
Whether the appellate courts failed to consider any reversible error in the trial court’s factual determinations and evaluation of the witness testimonies.