G.R. No. 181473 - People vs. Gaduyon y Tapispisan

The case involves an appellant, Doney Gaduyon y Tapispisan, accused of sexually abusing his 12-year-old daughter on three separate occasions.
The crimes charged include qualified rape by sexual intercourse, qualified rape by sexual assault (object rape), and sexual abuse, all committed against his own daughter.

Criminal Case No. 6572 for Qualified Rape (rape by sexual intercourse) on August 22, 2002, wherein he allegedly used force, threat, and intimidation by taking advantage of his moral authority and familial relationship.
Criminal Case No. 6573 for Sexual Abuse on August 21, 2002, alleging that while his daughter was alone with him, he fondled her breasts and touched her arms with a lewd design, accompanied by a threat not to disclose the incident.
Criminal Case No. 6574 for Qualified Object Rape on October 9, 2002, alleging that while his daughter was sleeping, he forcibly inserted his finger into her vagina.

The incident on August 21, 2002 where she was in bed and her father fondled and touched her, with his threat to silence her by warning that harm may come to her mother.
The incident on August 22, 2002 when, still alone in the residence, her father removed her shorts and panty; inserted his penis into her vagina twice causing her pain and repeated threats.
The incident on October 9, 2002 when, despite being in a family residence with her sister present in another part of the bed, she was awakened to find her father beside her; he then inserted his index finger into her vagina.

A healed deep laceration in her private part was recorded.
A psychiatric evaluation indicated Post-traumatic Stress Disorder with Depressed Mood.

Testimonies of family members who were present or later corroborated details of family whereabouts on the pertinent dates.
The victim’s credible, albeit emotionally charged, and consistent testimony despite minor inconsistencies.

Claimed that his wife and younger daughters were with him at the residence during the alleged incidents.
Asserted that he was engaged at his computer shop during the August 21 incident and that on August 22 his family’s presence negated the possibility of a rape in seclusion.
Contended that the October 9 incident was a misinterpretation as he was attending to household duties and that the victim’s account was induced by his wife due to marital infidelity.

The defense attempted to discredit the victim’s testimony by highlighting alleged conflicting accounts and inconsistencies in the details rendered.

The Regional Trial Court (RTC) rendered a decision on January 18, 2006, convicting the appellant based largely on the victim’s candid and corroborated testimony.
The RTC imposed severe penalties including the death sentence (later modified due to subsequent legal developments) or reclusion perpetua and awarded significant damages to the victim.
On appeal, the Court of Appeals (CA) affirmed in toto the RTC decision, rejecting the appellant’s defenses and emphasizing that the victim’s testimony held probative value despite minor discrepancies.

Whether the minor victim’s detailed testimony, despite minor inconsistencies, was sufficiently credible to establish guilt beyond reasonable doubt.
The impact of the victim’s emotional state and delayed recollection on the accuracy of her account.

Whether the testimonies, combined with physical and psychiatric findings, amounted to proof of rape by sexual intercourse, rape by sexual assault, and sexual abuse.
Whether appellant’s alibi and defense assertions were adequately supported by evidence to overcome the victim’s testimony.

Whether the elements of qualified rape under Article 266-A of the Revised Penal Code and sexual abuse under Republic Act No. 7610 were proven beyond reasonable doubt.
Whether the penalty imposed, later modified in view of statutory changes (such as the abolition of the death penalty), was appropriate given the circumstances of the case.

Whether minor inconsistencies in the victim’s narrative could serve as grounds for acquittal or detract from the conclusiveness of the testimony.
Whether corroborative evidence from medical and psychiatric examinations sufficiently bolstered the victim’s account.