Title
People vs. Masagca, Jr. y Padilla
Case
G.R. No. 184922
Decision Date
Feb 23, 2011
A father was convicted of raping his daughter, with the Supreme Court upholding the conviction and adjusting damages in light of the victim's credible testimony.
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Case Digest (G.R. No. 184922)

Facts:

  • Porferio Masagca, Jr. (appellant) was charged with three counts of rape against his daughter, referred to as AAA.
  • The incidents occurred in Barangay Sto. Domingo and Barangay J.M. Alberto (Poniton), Virac, Catanduanes.
  • First incident: On September 10, 2000, Masagca raped AAA after his other children left the room, threatening her to remain silent.
  • Second incident: On October 6, 2001, Masagca again raped AAA after awakening her, using threats to ensure compliance.
  • Third incident: On October 14, 2001, Masagca repeated the act of rape under similar circumstances.
  • AAA disclosed the incidents a week later to her aunt, leading to the filing of charges.
  • The prosecution presented AAA's testimony and a physician who confirmed hymenal lacerations.
  • Masagca's defense was based on alibi and denial, claiming AAA fabricated the charges after being disciplined.
  • The Regional Trial Court (RTC) found AAA's testimony credible and convicted Masagca, sentencing him to reclusion perpetua for each count and ordering damages.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed Masagca's conviction for three counts of rape, upholding the RTC's and Court of Appeals' findings.
  • The Court modified the awards of moral and exemplary damages, increasing the...(Unlock)

Ratio:

  • The Supreme Court emphasized the credibility of AAA's testimony, particularly in incestuous rape cases, where the victim's account is given significant weight.
  • The prosecution successfully established the elements of rape, with AAA positively identifying her father as the perpetrator.
  • The Court noted that a victim's testimony can suffice for conviction if credible and consistent with human experience.
  • Masagca's defenses of denial and alibi were deemed weak and insufficient, lacking strong evidence of innocence.
  • The...continue reading

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