Facts:

• Jose Estalin Prodenciado was charged with two counts of Statutory Rape and two counts of Simple Rape against his daughter, referred to as aAAAa.
• The incidents occurred in Baliuag, Bulacan, with the first rape happening in 1993 when aAAAa was eight years old.
• The second incident of Statutory Rape occurred in 1995 when she was ten years old.
• The Simple Rape incidents took place on August 13, 2000, when aAAAa was fourteen.
• The prosecution relied on aAAAa's testimony, detailing threats made by her father, forced sexual acts, and intimidation against her mother.
• The Regional Trial Court (RTC) found Prodenciado guilty on May 25, 2007, sentencing him to reclusion perpetua for each count and ordering monetary damages to the victim.
• Prodenciado appealed to the Court of Appeals (CA), which affirmed the RTC's ruling but modified the civil liability amounts.
• The case was then brought before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court upheld Prodenciado's conviction for one count of Statutory Rape and three counts of Qualified Rape.
• The penalties imposed by the lower courts, including reclusion perpetua without eligibility for paro...(Unlock)

Ratio:

• The Supreme Court highlighted the credibility of the victim's testimony, emphasizing that child-victims' accounts are given significant weight due to their vulnerability and trauma.
• The Court noted that the trial court is best positioned to assess witness credibility, particularly in cases involving minors.
• It ruled that the date of the crime is not an essential element of rape, and delayed reporting does not negate the occ...continue reading