G.R. No. 80728 - Pearl S. Buck Foundation, Inc. vs. National Labor Relations Commission

Accused-appellant Danilo Tuyor y Banderas was charged with multiple counts of rape against AAA, a minor aged 14 at the time of the alleged crimes.
The charges were filed based on five separate Informations, each alleging that between July and October 2007 the accused, motivated by lust and using force, threat, and intimidation—while taking advantage of his moral ascendancy—carried out acts amounting to carnal knowledge on his stepdaughter.
Although AAA was claimed to be his stepdaughter, the relationship was characterized as such because Tuyor was the live-in partner of AAA’s mother, CCC, and not her legally married spouse; hence, the special qualifying circumstance of a stepfather-stepdaughter relationship was contested.

AAA testified that around 9:30 p.m. she was in the room with her siblings when Tuyor asked all other siblings to leave, leaving her alone.
Tuyor allegedly closed the door, removed AAA’s clothing, and forcibly pinned her thighs before inserting his penis into her vagina.
Following the act, he wiped his genitalia with a cloth to remove traces of blood and threatened to kill her siblings and mother if she disclosed the incident.

Second Incident (August 2007): AAA recalled being asleep when she felt someone on top of her; upon opening her eyes, she recognized Tuyor, who then inserted his penis into her vagina, covered her mouth, and held her hands, all while threatening her.
Third Incident (September 24, 2007): Testimony was interrupted by heightened emotions during the alleged rape while AAA was performing chores, resulting in an incomplete account due to her continuous crying.
Fourth Incident (September 29, 2007): AAA testified that at about 10:05 p.m. she was about to sleep on the floor when Tuyor re-entered the room after ordering her siblings out; he subsequently covered her mouth and raped her by pinning and forcibly inserting his genital organ.
Fifth Incident (October 24, 2007): While AAA was sleeping, Tuyor allegedly lay down beside her, removed part of her clothing, and repeatedly inserted his penis; during the act, she felt his hand on her breast and noted the presence of a whitish substance from his organ.

Testimony of the victim, AAA, was central and detailed, describing the physical and emotional circumstances during the alleged crimes.
Forensic evidence included AAA’s certificate of live birth (establishing her age), a medico-legal report by Dr. Irene Baluyut (documenting signs of sexual abuse and pregnancy), and a series of photographic exhibits from the Child Protection Unit of the Philippine General Hospital (PGH).
Testimony from Dr. Bernadette J. Madrid of the PGH’s Child Protection Unit, who confirmed the authenticity of Dr. Baluyut’s findings and signature, supported the evidentiary value of the medico-legal report.

Tuyor pleaded not guilty and, after being given ample time to present evidence, his counsel chose not to introduce additional evidence to counter the prosecution’s presentation.

The Regional Trial Court (RTC) of Bacoor City, Branch 89, rendered a decision on October 9, 2015:

Found Tuyor guilty beyond reasonable doubt in four of the five counts of rape (one count resulted in acquittal due to insufficient proof).
Imposed reclusion perpetua as the penalty on each count where conviction was rendered.
Awarded damages in the form of civil indemnity, moral damages, and exemplary damages for the counts found guilty.

Modified the award by increasing damages to ₱100,000 each per count.
Reiterated that the medico-legal report was admissible and that Dr. Madrid’s testimony was properly given weight as both an expert and a witness familiar with Dr. Baluyut’s work.

The admissibility of Dr. Madrid’s testimony as hearsay.
The weight and credibility given to the victim’s testimony.
The conviction for qualified rape, contending that only the elements for simple rape had been proven.

Whether the Court of Appeals erred in not excluding Dr. Bernadette J. Madrid’s testimony on the ground that it was hearsay, given that she was not present during the preparation of the medico-legal report or AAA’s medical examination.
Whether the Court of Appeals improperly gave due weight and credence to AAA’s testimony despite alleged inconsistencies, particularly regarding the timing of the second incident of rape.
Whether the CA erred in convicting the accused of qualified rape, especially considering that the requisite stepfather–stepdaughter relationship was not legally established, thereby reducing the crime to simple rape under the law.