G.R. No. 228822 - People vs. CCC

The case involves appellant CCC, who was charged in four separate Criminal Cases (Nos. 2566, 2567, 2568, and 2569) for the crime of rape committed against his daughter, AAA.
Each count alleged that CCC, by means of force and intimidation, had carnal knowledge of AAA, who was 12 years old at the time of the incidents, thereby invoking the aggravating circumstance that the offender is her own father.
The specific alleged incidents occurred on different dates in January and February 2004, at around 10:00 to 11:00 o’clock in the evening in a locality in Romblon, Philippines.

As the Municipal Health Officer, Dr. Dianco conducted a physical and genital examination on AAA on 19 March 2004.
She observed that AAA’s hymen was ruptured although healed, opining that the penetration likely occurred approximately one month before the examination.
The medico-legal certification prepared during this examination was duly introduced as evidence.

BBB testified that CCC was AAA’s father and provided background information regarding their marital status and the use of AAA’s maiden name.
She supported her testimony by identifying AAA’s Certificate of Live Birth, which established AAA’s age as 12 years at the time of the first incident.
BBB described noticeable changes in AAA’s behavior such as increased quietness, aloofness, and a state of shock after the alleged incidents.
She also reported a marked change in CCC’s behavior, who reportedly no longer stayed at home subsequent to the incidents.
BBB introduced a handwritten letter allegedly written by AAA in which AAA hinted at being abused by her father, using terms like “MANYAK” and expressing despair over the actions of her “KWENT HIYANG AMA.”

AAA’s testimony was initially scheduled but was repeatedly postponed and cancelled due to various reasons such as inclement weather, financial inability to attend court, and refusal to sign subpoenas by both AAA and BBB.
Ultimately, AAA’s testimony was expunged from the records for lack of cross-examination, leaving her direct account unpresented in court.

Multiple hearings were cancelled or postponed, often due to the unavailability of either BBB or AAA, and due to issues with properly serving subpoenas.
Despite these procedural issues, the prosecution formally offered the exhibits (the Medico-Legal Certification, the Certificate of Live Birth, and the handwritten letter) on 22 January 2013.
CCC, on his part, waived his right to present evidence through his counsel.

In its Consolidated Decision dated 20 August 2013, the RTC found CCC guilty beyond reasonable doubt of all four counts of rape.
The RTC relied primarily on BBB’s testimony about AAA’s disclosures and behavioral changes, the medico-legal findings of Dr. Dianco, and the identification of the handwritten letter.
CCC was sentenced to suffer the penalty of death (later commuted under RA No. 9346 to reclusion perpetua, without eligibility for parole) and was ordered to pay civil indemnity, moral damages, and exemplary damages in favor of AAA.

On 22 June 2016, the CA affirmed, with modifications as to the penalty, the RTC’s consolidated decision but increased the amounts for damages payable to AAA.
The CA reaffirmed the reliance on the handwritten letter, BBB’s identification of the letter, and the corroborative physiological evidence provided by Dr. Dianco.
Despite recognizing that much of BBB’s evidence about what AAA had disclosed was hearsay, the CA held it adequate to convict CCC of qualified rape.

CCC filed a Motion for Reconsideration on 26 November 2013, which was denied by the RTC in February 2014.
CCC then appealed to the Court of Appeals, highlighting issues particularly with the evidentiary basis of his conviction, especially the lack of direct testimony from AAA and the reliance on hearsay evidence.
Subsequently, CCC elevated the appeal before the Supreme Court.

Whether the Court of Appeals committed a grave error in affirming the conviction of CCC beyond reasonable doubt for the crime of rape.
Whether the elements of qualified rape, particularly the requirement of proving that CCC had carnal knowledge of AAA, were sufficiently established by the evidence on record.
Whether the reliance on the handwritten letter of AAA and BBB’s hearsay testimony regarding AAA’s allegations and behavior changes can support a finding of guilt beyond reasonable doubt.
Whether the absence of AAA’s direct testimony, due to its expungement from the record, undermines the prosecution’s case and the consequent conviction.