G.R. No. 175831 - People vs. Relanes

The case involves appellant Florante Relanes, also known as "Dante," who was charged with two counts of rape committed against his daughter, designated "AAA."
Two separate Informations were filed on March 14, 2003:

Criminal Case No. 2003-5882 alleged that during the first week of August 2002, at Barangay "CCC" in Municipality "DDD," Province "EEE," the appellant raped his 13-year-old daughter using force, threat, and intimidation, including the use of a bolo.
Criminal Case No. 2003-5883 alleged that on January 9, 2003, at the same locale, the appellant again raped his 14-year-old daughter under similar circumstances, which resulted in her being impregnated.

Upon arraignment, the appellant pleaded not guilty to both charges, and the two cases were tried jointly.

"AAA" testified in detail about the repeated rape incidents beginning when she was as young as eight years old, describing how her father would sexually abuse her whenever her mother was away vending vegetables.
She disclosed that the abuse typically occurred on Thursdays, around 7:00 p.m., and on occasions when she was alone at home.
Her account included explicit descriptions of the acts – from undressing, being forcibly mounted, to the insertion of his penis with a push and pull movement – as well as explicit threats made to prevent her from reporting the abuse.

Dr. Ronald Lim, the Municipal Health Officer, testified that upon examining "AAA" on January 27, 2003, he found healed lacerations on her genitalia consistent with sexual intercourse.
His report confirmed the pregnancy and physical evidence supporting the occurrence of rape.

"BBB" testified confirming her marriage to the appellant and that "AAA" was their daughter.
She recounted the incident’s discovery when "AAA" informed her of the rape and the subsequent steps taken, including the arrest of the appellant.

Initially, the appellant denied engaging in any rape on the August 2002 date, later partially admitting to having sexual intercourse under those circumstances.
The appellant maintained his alibi for the January 9, 2003 incident, asserting that he had already left for Manila and could not have committed the rape on that day.
His defense largely relied on disputing the credibility of "AAA’s" testimony and asserting that the prosecution failed to prove his guilt beyond reasonable doubt.

At the Regional Trial Court (RTC), Branch 51 of Sorsogon City, the testimony of "AAA" was deemed consistent and credible, leading to the finding of guilt beyond reasonable doubt for both criminal counts.

The RTC sentenced the appellant to suffer the penalty of double death and imposed damages on "AAA" in the form of civil indemnity, moral, and exemplary damages.

It held that the victim’s testimony was clear, positive, and consistent, warranting the conclusion that the appellant had raped his daughter on both occasions.
The CA modified the penalty by confirming the imposition of the death penalty but adjusted the damages amounts accordingly.

The case was elevated to the Supreme Court on automatic review, with parties subsequently filing supplemental briefs as provided in the rules for automatic review.

Whether the trial court erred in giving full weight and credence to the testimony of the private complainant, "AAA."
Whether the alleged inconsistency concerning the timing of school attendance versus the occurrence of the alleged rape on January 9, 2003, undermines the credibility of her testimony.

Whether the prosecution sufficiently and convincingly proved the appellant’s guilt beyond reasonable doubt.
Whether the appellant’s defenses—his denial, partial admission, and alibi—failed to dispel the prosecution’s case.

Whether the appellant’s plea for forgiveness to family members could be taken as an implied admission of guilt.