G.R. No. 222492 - People vs. XXX

The case involves appellant XXX, who was charged with rape against his daughter, complainant AAA, a minor aged 13 at the time of the offense.
The Information complained that on August 19, 2009, in Quezon City, appellant, by force and intimidation, committed rape by inserting his organ into his daughter’s private parts against her will.
The Information also mentioned previous incidents of alleged rape committed by appellant in March 2007 and 2008, establishing a pattern of abuse, although the present case centers on the incident on August 19, 2009.

The case was raffled to the Regional Trial Court of Quezon City, Branch 107, and docketed as Criminal Case No. Q-09-160296.
At arraignment, appellant pleaded “not guilty.”
The trial court rendered a verdict on December 3, 2013, convicting appellant of qualified rape and sentencing him to reclusion perpetua (without eligibility for parole), along with orders to pay civil indemnity, moral, and exemplary damages.
The Court of Appeals affirmed the trial verdict, with modifications to the damages awards and confirmation of the sentence.

Complainant AAA testified detailing how on the night of August 19, 2009, after attempting to wake her brother CCC to turn off the light, she returned to find her father blocking her way.
According to her account, appellant:

ii. Held her hand and forced her to lie on his “higaan” (sleeping area); iii. Removed her t-shirt, shorts, and underwear before forcibly raping her.

Complainant described the painful experience, noting that despite her pleas, appellant continued the act, later instructing her to cook rice after the incident.

The family resided in a small, one-room house in a squatters area where the living area served as both the bedroom and common area.
At the time of the incident, the complainant, her brother, and appellant were all sleeping in the sala (living area); her mother and younger sibling had already left for work.

The following day, in an effort to avoid her father, complainant left home and reported the incident to her friend Carmina Morales, who later accompanied her to the barangay office.
The barangay officials, after hearing the victim’s account, arranged for the arrest of appellant at his workplace, and the complainant underwent a medico-legal examination that later revealed hymenal lacerations consistent with blunt penetrating trauma.

The prosecution introduced multiple exhibits to establish the credibility of the testimony:

Complainant’s affidavit detailing the incident.
Birth certificate establishing the complainant’s age, reinforcing the element of minority.
Medical reports including an Initial Medico-Legal Report and a subsequent PNP Crime Laboratory Medico-Legal Report confirming the physical injuries.

Witness testimonies from barangay tanods and others provided additional corroboration of the allegations.

The complainant’s testimony was not straightforward or categorical enough, especially regarding the absence of witnessed penile penetration.
He claimed an alibi by alleging he was at his workplace during the incident and contended that he could not have harmed his daughter.

The defense failed to present any documentary evidence to support its claims, relying solely on denial and an unsubstantiated alibi.

The sufficiency of the prosecution’s evidence regarding the element of carnal knowledge, specifically in proving that penile penetration occurred despite the complainant’s mixed testimony on the physical act.
The reliability and credibility of the complainant’s testimony as the primary evidence, especially given her familial relationship with the accused, and the alleged inconsistency in her actions post-incident (e.g., not shouting for help).
The contention of whether the defense’s denial and alibi, lacking substantive documentary support, could negate the prosecution’s evidence.