G.R. No. 120625-29 - People vs. Marahay y Moraca

The case involves accusations by the People of the Philippines against Carlito Marahay y Moraca for multiple counts of rape committed against his own daughters, AAA (aged 12) and BBB (aged 14).
The charges were consolidated from five separate criminal cases (Nos. 1964, 1965, 1967, 1968, and 1969) filed in the Regional Trial Court, Branch 19, Catarman, Northern Samar.

Accused allegedly raped his daughter AAA on August 24, 1994, by kissing, embracing, and inserting his finger before attempting penetration with his penis.
Testimony from AAA described the sequence where her father removed her shorts and panty and attempted further sexual advances.

Accused is charged with having carnal knowledge of BBB on the evening of August 24, 1994, by forcibly kissing, embracing, and touching her intimate parts.

Additional actions on August 24, 25, and 26, 1994 where BBB testified that her father repeatedly assaulted her.
The charges include instances where BBB was allegedly raped during different times (evening and early morning) and in more than one incident.
The prosecution presented testimony describing explicit details of the sexual assault, including the use of physical restraint and force.

The trial record includes detailed testimonies from BBB and AAA describing physical and emotional distress, struggles to resist, and the overwhelming use of force.
Medical examinations later noted healed hymenal lacerations in positions corresponding to the alleged insertions, supporting the accounts of sexual abuse.
The defense, however, presented the accused-appellant as its sole witness, claiming that his wife fabricated the rape charges due to personal vendetta and domestic issues.
The accused asserted that an inexplicable “devilish possession” caused him to commit the acts, emphasizing lack of intent to overpower by force.
The pre-trial stipulation recognized that the accused and the complainant, Amalia Marahay, were legally married and that the victims were indeed their legitimate children.

Initial filing of two Informations on November 24, 1994, followed by three amended complaints on November 29, 1994, to include additional charges against BBB.
During trial, significant reliance was placed on the victims’ testimonies which were corroborated in part by the confession-like admissions of the accused regarding one incident of the assault against BBB.
The evidence presented included detailed chronological testimony, photographic/medical reports and recorded inconsistencies in the defense’s narrative regarding motive and credibility.

Under Article 335 of the Revised Penal Code (as amended by RA No. 7659), the crime of rape is defined; special circumstances such as the relationship between the perpetrator and the victim (father–daughter) may warrant severe penalties including the death penalty if accompanied by the victim’s minority.
Despite the allegations, the prosecution failed to establish, through independent evidence, the precise age of the victims required for the imposition of the death penalty.
The trial court initially sentenced the accused to death for each count and awarded moral and exemplary damages to the victims; however, these determinations were later revised on appeal.

Whether the prosecution proved beyond reasonable doubt every element of each separate count of rape, especially in cases where the victim’s testimony was vague or insufficiently detailed.
Whether the repeated occurrences allegedly described by BBB meet the threshold for distinct counts or are part of a continuous act.

The reliability and consistency of BBB’s and AAA’s testimonies, given the traumatic nature of the assault and the possibility of coaching or external influence.
The role of the accused’s contradictory statements in corroborating or undermining the victim accounts.

Whether the qualifying circumstance of the victims’ minority, which automatically imposes the death penalty under RA No. 7659, was sufficiently established by independent evidence.
Whether the father-daughter relationship alone suffices for aggravation, or if the element of minority must be decisively proven.

Whether moral damages and civil indemnity should be awarded automatically based on the fact of rape, and if so, the proper quantum given the evidentiary record.
The propriety of awarding exemplary damages considering established precedents and aggravating circumstances.

Whether each incident of rape should be considered a distinct crime or if there is overlap that would subsume some charges under a single occurrence.
The accuracy of the interrogatories regarding the timing and circumstances of the alleged assaults, particularly in Criminal Cases Nos. 1965 and 1969.