Case Digest (G.R. No. 225059)
Facts:
People of the Philippines v. XXX, G.R. No. 225059, July 23, 2018, the Supreme Court Second Division, Caguioa, J., writing for the Court.
The prosecution charged XXX (accused-appellant) by four separate informations for rape under Article 266-A, par. 1, in relation to Article 266-B, par. 2, of the Revised Penal Code, as amended by Republic Act No. 8353 and in relation to RA 7610, for four distinct acts of sexual intercourse committed against his daughter, BBB (private offended party). The informations allege incidents spanning 2004, 2005 (twice) and May 18, 2010, occurring in Valenzuela City; the complaints describe force and intimidation (including a knife) and threats to kill BBB’s mother if she reported the acts.
Upon arraignment XXX pleaded not guilty and trial on the merits proceeded at the Regional Trial Court (RTC) of Valenzuela City, Branch 270, Criminal Case Nos. 671‑V‑10 to 674‑V‑10. BBB testified in detail about the four incidents, describing the use of a knife, threats, physical restraint, the sexual acts and resulting pain; she later gave a sworn statement and underwent medico‑legal examination. The medico‑legal report documented a deep healed laceration of the hymen and opined that findings were consistent with the victim’s history.
XXX denied the allegations at trial, asserting BBB was influenced by a friend and alleging that BBB later recanted (an assertion he did not corroborate by documentary evidence or witness testimony). The RTC, after assessing credibility, found BBB’s testimony straightforward and credible and convicted XXX of all four counts of rape, sentencing him to reclusion perpetua for each count and awarding P75,000 civil indemnity, P75,000 moral damages, and P30,000 exemplary damages for each count, to be served concurrently and with credit for preventive imprisonment.
XXX appealed to the Court of Appeals (CA) via Notice of Appeal. The CA, in CA‑G.R. CR‑HC No. 05783, rendered its decision on July 24, 2015, affirming the RTC’s conviction but modifying the awards: it retained reclusion perpetua for each count and ordered P75,000 civil indemnity, P75,000 moral damages and P30,000 exemplary damages for each count, and added legal interest of six percent per annum on the total monetary award. XXX elevated the case to the Supreme Court by appeal under Section 13(c), Rule 124 of the Rules of Court.
The sole issue framed before the Supreme Court was whether XXX’s guilt for the four counts of rape was proven beyond reasonable doubt. The Supreme Court heard the appeal and issued the dispositive decision under review.
Issues:
- Was the guilt of accused‑appellant XXX for the four counts of rape proven beyond reasonable doubt?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)