Facts:

• Juanito Dela Cruz y Rivera is the accused-appellant, and his daughter, AAA, is the victim.
• Four separate charges of rape were filed against Dela Cruz for incidents occurring between March 1995 and July 1998.
• The first incident happened on March 8, 1995, when AAA was 16 years old, during a family celebration where Dela Cruz, intoxicated, assaulted her.
• AAA testified that she was raped multiple times in 1996 and 1997 by her father.
• The last incident occurred on July 24, 1998, in a nipa hut where AAA and her siblings were sleeping.
• AAA and her mother reported the incidents to the National Bureau of Investigation (NBI) on July 30, 1998.
• The prosecution presented AAA's testimony, supported by a medical examination by Dr. Armie Soreto-Umil.
• The Regional Trial Court (RTC) convicted Dela Cruz of rape, sentencing him to death in two cases and reclusion perpetua in the other two.
• The case was automatically reviewed due to the death penalty, and the Court of Appeals later modified the RTC's decision.

Issue:

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Ruling:

• The Supreme Court affirmed the Court of Appeals' decision, modifying the RTC's ruling.
• Dela Cruz was found guilty of simple rape instead of qualified rape due to insufficient proof of AAA's minority.
• The penalty was reduced to reclusion perpetua for the counts where the death penalty was initially imposed.
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Ratio:

• The Supreme Court emphasized the importance of the victim's credibility in rape cases, stating that corroboration is not strictly necessary if the testimony is clear and convincing.
• Minor inconsistencies in AAA's testimony did not undermine her credibility, as they related to non-essential details.
• The absence of physical injuries was de...continue reading