G.R. No. 173259 - Philippine National Bank vs. F.F. Cruz and Co., Inc.

The case originates from two criminal cases (Criminal Case Nos. 11-0539 and 11-0541) filed against Romeo De Guzman y De Castro for two counts of Qualified Rape committed under Article 266-A in relation to Article 266-B of the Revised Penal Code.
Two separate sets of Information were filed, and the accused pleaded not guilty to both charges.
The complaint detailed that the crime occurred in two distinct periods:

In 2003, when the victim, AAA (then 8 years old), was sexually assaulted by her stepfather in Las PiAas City.
Repeated sexual abuses from 2006 to 2010 when the victim was between 11 to 15 years old.

In the 2003 incident, De Guzman led AAA to an isolated part of their residence, removed her clothes, and committed rape by forcibly inserting his penis into her vagina.
After the act, he threatened the minor to keep silent, exploiting his position as her stepfather and thus her moral superior.
The repeated abuse from 2006 to 2010 followed a similar pattern of using force, threat, and his influential position as a step-parent, reinforcing the abuse and the victim's vulnerability.

AAA testified in open court detailing the incidents, including the initial rape at age 8 and the subsequent abuses.
Her testimony was corroborated by her aunt, CCC, who affirmed AAA’s account of the sexual abuses.
Medical evidence provided by Dr. Editha Martinez of the Philippine National Police Crime Laboratory recorded lacerations on the victim’s hymen, consistent with abuse by a blunt, hard object such as a finger or an erect penis.

The accused, De Guzman, denied the commission of rape, offering defenses of both denial and alibi, claiming he was in Pangasinan during the alleged incident in 2003 and was never left alone with AAA during the later period.
BBB, the victim’s mother, also testified in support of her husband’s defense by affirming the imputation of bad behavior and substantiating his version of events.

The Regional Trial Court (RTC) of Las PiAas City found De Guzman guilty beyond reasonable doubt on both counts, sentencing him to reclusion perpetua for each offense and ordering the payment of exemplary damages to AAA.
The Court of Appeals (CA) modified the trial court’s decision by increasing the monetary awards, while still affirming the conviction and the imposition of reclusion perpetua without parole.
On appeal, the Supreme Court, after a thorough review of the records, dismissed the appeal for lack of merit and affirmed the findings and penalties rendered by the lower courts.

Whether the prosecution was able to prove beyond reasonable doubt that De Guzman committed the acts of rape as charged.
Whether the testimony of the victim AAA and her corroborative statements were credible and sufficient to sustain conviction.

Whether De Guzman’s alibi—that he was in Pangasinan during the purported incident—was supported by credible evidence.
Whether the defense’s claim that the victim’s alleged bad behavior and ill motives influenced her testimony held any merit.

Whether the moral ascendancy of the accused as a stepfather could substitute for the absence of actual physical force, threat, or intimidation in the commission of the crime of rape.

Whether the lack of precise reference to date and time in the Information undermined the elements of the crime of rape, considering that precision is not a required element for a conviction in rape cases.