G.R. No. 199210 - People vs. Vidana

The case involves the People of the Philippines as Plaintiff-Appellee and Ricardo M. VidaAa as Accused-Appellant.
The decision was rendered by a panel including Justice Leonardo-de Castro and was subsequently affirmed on appeal by the Court of Appeals.
The matter originated from the conviction of VidaAa by the RTC of Guimba, Nueva Ecija, Branch 33 in Criminal Case No. 2163-G for one count of rape under Republic Act No. 7610, also known as the Special Protection of Children Against Abuse, Exploitation and Discrimination Act.
The appeal is based on the single assignment of error raising issues on the conviction under Section 5 in relation to Section 31 of RA 7610.

The information alleges that on or about September 16, 2003, at a residence in Nueva Ecija, the accused, with lewd designs and intent for carnal knowledge, raped his minor daughter [AAA] who was 15 years old.
The fact-finder noted that the accused abused his position and influence as a father against the will of the minor, doing so in a context that involved coercion through covering her mouth, removing her clothes, and inserting his penis into her vagina.
The victim's testimony described the incident as taking place in the sala of the house where the family resided, at almost midnight during an interval when the other children were asleep.

The prosecution narrated events as witnessed by [AAA], who recounted that she was forcibly pulled from her bed, taken to the sala, and deprived of her garments.
Her testimony detailed the physical sequence of rape, including the use of threats such as the accused warning her not to disclose the incident for fear of harm to her and her siblings.
Emotional testimony was marked by tears and a breakdown during her recounting of the ordeal, which was later affirmed by the trial court and the Court of Appeals.

The accused argued that on the date of the incident, he was harvesting in the fields with his common-law wife, corroborated in part by his son [EEE].
He maintained that the minor was not residing with him at the time and questioned the credibility of the victim’s account, particularly denying any evidence of resistance during the act.
The defense hinged its argument on the inconsistency in the victim’s narration and attempted to use both denial and an alibi as bases for acquittal.

After trial on the merits, the RTC found the accused guilty beyond reasonable doubt of rape against his own daughter and sentenced him to reclusion perpetua.
The trial also awarded moral damages of P50,000 to the victim.
The Court of Appeals affirmed the RTC’s decision and reaffirmed the credibility of the victim’s testimony despite the accused’s earnest denials and attempt to present an alibi.
The factual record, including detailed transcript excerpts of [AAA]’s testimony, played a significant role in reaffirming the findings.

Whether the victim’s (AAA’s) testimony, delivered amid evident emotional distress, is credible, convincing, and consistent with the established facts of the case.
Whether the absence of overt physical resistance (shouting, struggling) by the victim detracts from the credibility of her account given the nature of paternal influence and moral ascendancy.

Whether the defendant’s assertion that he was elsewhere (harvesting in the fields) and his denial based on his son’s corroboration (a relative with potential conflict of interest) can override the victim’s testimony.
Whether the inherent weakness of alibi and denial in rape cases, without corroboration from disinterested witnesses, suffices to create reasonable doubt.

Whether the trial court erred in the implied characterization of the offense charged as sexual abuse under Sections 5 and 31 of RA 7610 instead of the proper offense of rape under Article 266-A of the Revised Penal Code.
The implications of such designation on the applicable penalty, particularly regarding reclusion perpetua versus the death penalty and the subsequent imposition of damages.