G.R. No. 208091 - People vs. Molejon

The accused-appellant, Benito Molejon, was charged in five separate informations with qualified rape and in 11 separate informations with acts of lasciviousness.
The rape charges involved two stepdaughters: three counts against his 13‐year-old stepdaughter (designated as AAA) and two counts against his 11‐year-old stepdaughter (designated as BBB).
The acts of lasciviousness were similarly alleged in 11 counts, with eight incidents involving AAA and three involving BBB, though slight differences in ages and dates were noted.

The allegations, commencing in or about the 1st week of January 2003 at Barangay Busay, Isabela City, stated that by force, threat, and intimidation, the accused had carnal knowledge of AAA against her will.
Aggravating circumstances included the victim’s young age, the familial relationship (stepfather), and the use of force and intimidation.

The initial information dated on or about June 28, 2003, described how the accused, driven by lust, committed lascivious acts on an 11-year-old by means of touching and fingering, before escalating to involve penetration in later counts.
Subsequent informations contained similar allegations, differing only in the specific dates and the age of the victim (either under 12 or over 12 but still a minor).

Victim AAA testified that from July 2001 up to January 2003, she endured a series of sexual abuses by the accused, including kissing, caressing, and eventually a forceful sexual act that caused her pain and distress.
Victim BBB provided an almost identical account, detailing events from October 2002 to June 2003 that included similar lascivious acts, with explicit mentions of forced insertion and bodily fluids.
Both victims testified that the accused threatened to kill them, their mother, and siblings if they disclosed the incidents.
CCC, the mother of the victims, intervened on June 28, 2003, after witnessing the accused assaulting BBB, which led to the disclosure of the full extent of the abuse.
Medical evidence, notably the findings of healed hymenal lacerations documented by Dr. Barandino, corroborated the victims’ testimonies regarding prior rape incidents.

During arraignment, the accused pleaded not guilty to all charges, arguing that no explicit threats were made during the incidents and questioning the credibility of the minor victims.
The defense also raised the issues of alleged inconsistencies in the victims’ accounts and maintained an alibi, contending that the mere recollection of pain without witnessing explicit penetration was insufficient to prove rape.
The trial court (RTC) rendered its decision on August 5, 2010, convicting him on the counts of qualified rape and acts of lasciviousness.
The Court of Appeals (CA) affirmed the RTC’s decision with modifications concerning penalties and awards of damages, particularly reflecting adjustments in nomenclature and the quantum of indemnity, moral, and exemplary damages.
On appeal, the Supreme Court reviewed the entire record, reaffirming the factual findings of both lower courts and giving significant weight to the direct and candid testimonies of the minor victims.

Whether minor inconsistencies in the testimonies of child victims (AAA and BBB) vitiate their overall credibility and reliability.
Whether the detailed and candid recollections, despite slight discrepancies, sufficiently establish the commission of qualified rape and acts of lasciviousness.

Whether the cumulative testimonies, supported by medical evidence and circumstantial facts, meet the threshold of proof beyond reasonable doubt for the charges filed.
Whether the alleged lack of explicit physical resistance or vocal denunciation by the victims undermines the prosecution’s case.

Whether the defense’s reliance on denial and alibi effectively challenges the integrity of the witnesses’ accounts.
Whether the defense’s argument regarding the absence of overt threatening words or a weapon is legally sustainable in light of the established framework of rape (including moral and psychological intimidation).

Whether the modifications in the penalty and the awards rendered by the CA—especially regarding the differentiation between qualified rape and acts of lasciviousness—are supported by both the facts and applicable law.
Whether the adjustment in the nomenclature of the offenses (e.g., lascivious conduct versus acts of lasciviousness) in relation to the victim’s age is legally justified.