G.R. No. 207231 - People vs. Galagati y Gardoce

On May 13, 2003, seven Informations were filed against Roger Gardoce Galagati for rape, with incidents dated September 13, October 8, 10, 11, 15, 22, and 25, 2002, in Kabankalan City, Negros Occidental.
The primary complainant was AAA, a minor around fifteen years old.

AAA was born September 11, 1987, to Susie Valenzona and Luciano Monasque, who were not legally married; Susie had Galagati as her common-law spouse ("live-in" partner).
AAA lived in her grandfather’s house with Galagati, her mother Susie, uncle, and three siblings. At the time of the incidents, AAA was a second-year high school student.

On September 13, 2002, at around 2:00 p.m., while alone in the changing room, Galagati forcibly had sexual intercourse with AAA, threatening to kill her mother and siblings to prevent disclosure.
AAA described penetration by Galagati’s penis causing bleeding and crying.
Subsequent incidents on October 8, 10, 11, 15, 22, and 25, 2002, involved sexual assaults primarily by penetration of the index finger and rubbing of the penis in the vagina.
AAA did not inform her mother or authorities earlier due to threats by Galagati.
She recalled dates based on school attendance and absence of family members at home.

Galagati denied all allegations, asserting that AAA’s presence at certain dates and times contradicted the charges.
Claimed love and care for AAA as his own child.
Alleged the charges were fabrications stemming from family disputes, especially a conflict with AAA’s uncle.

Only AAA testified for the prosecution; her testimony was not cross-examined.
The Regional Trial Court (RTC) found AAA’s testimony credible and convicted Galagati of rape for one count of carnal knowledge (September 13, 2002) and five counts of sexual assault via penetration with the index finger.
The RTC sentenced him to reclusion perpetua for the count of rape involving intercourse and imposed lesser sentences for other counts; damages and costs were awarded to AAA.

The CA affirmed conviction for the first count of rape (September 13, 2002) but reversed and acquitted Galagati on the five counts relating to sexual assault with the index finger.
The CA ruled that AAA’s testimony on the later dates was vague, shallow, and lacked details of force, threat, or intimidation.
The CA considered the absence of explicit indications of force or intimidation and ruled that the prosecution failed to prove guilt beyond reasonable doubt for these incidents.

Galagati appealed to the Supreme Court seeking overturning of the conviction on the first count.
The Supreme Court reviewed the case to determine the validity of the trial court’s findings on credibility and guilt.

Whether the trial court erred in finding Roger Gardoce Galagati guilty beyond reasonable doubt of the rape committed on September 13, 2002.

Whether the Court of Appeals committed an error in acquitting Galagati in the five counts of sexual assault through penetration involving the index finger dated October 8, 10, 11, 15, 22, and 25, 2002.

Whether the penalty of reclusion perpetua and the damages awarded were proper and justifiable given the facts and circumstances of the case.