Facts:

• The case is People vs. Saturnino Villanueva, decided on September 1, 2010.
• Villanueva was charged with three counts of qualified rape against his daughter, "AAA."
• The incidents occurred on September 27 and 28, 1999, and June 9, 2002, in Pangasinan, Philippines.
• "AAA" testified about enduring sexual abuse from her father since childhood.
• At the time of the last incident, "AAA" was 12 years old.
• Villanueva used threats and intimidation, including a bladed weapon, to perpetrate the acts.
• He pleaded not guilty during his arraignment on November 14, 2002.
• The Regional Trial Court (RTC) found him guilty and sentenced him to death, ordering damages to "AAA."
• The Court of Appeals (CA) later modified the sentence to reclusion perpetua due to the abolition of the death penalty under Republic Act No. 9346.

Issue:

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Ruling:

• The Supreme Court upheld Villanueva's conviction but reclassified it from qualified rape to simple rape.
• The Court found the prosecution's evidence, particularly "AAA's" credible testimony, sufficient for conviction.
• It ruled that the medical and birth certificates were improperly considered since they were not formally offered in court.
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Ratio:

• The Supreme Court stated that a rape conviction can be based solely on the credible testimony of the victim if it is convincing and aligns with human experience.
• "AAA's" testimony was found to be credible, detailed, and emotionally compelling.
• The Court noted that the medical and birth certificates, although marked as exhibits, lacked legal standing due to not being formally offered. ...continue reading