G.R. No. 225339 - People vs. XXX

On January 13, 2004, at around 3:00 in the morning in Camarines Sur, the accused, who is also the uncle of the victim, is alleged to have raped AAA, a 16-year-old minor.
The allegation involves the use of force and intimidation as the accused, during the incident, forcibly had carnal knowledge of AAA against her will.
The charge was framed under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, which specifically punishes rape.

The case was initially raffled to the Regional Trial Court – Branch 35 in Iriga City.
Appellant XXX pleaded “not guilty” upon arraignment.
Testimonies were heard from key witnesses:

AAA provided a detailed and harrowing account describing how, while asleep, she was unexpectedly attacked by the accused who proceeded with a “push and pull” movement inside her vagina, despite her resistance.
BBB (AAA’s mother) testified that upon turning on the light in the early morning she observed appellant moving her youngest child and later discovered AAA in a compromising situation, which led her to question the events.
Medical evidence was presented when Dr. Marie Anne Ng-Hua conducted an examination on AAA and attested to the presence of hymenal lacerations at the 3, 6, and 9 o’clock positions.
Other witnesses included law enforcement personnel and a social worker (Guadalupe Bisenio), who assisted in the procedural follow-ups such as filing the complaint and coordinating the medical examination.

Documentary exhibits including AAA’s birth certificate, the letter-request for a medical check-up prepared by DSWD, and the medical certificate by Dr. Ng-Hua were introduced to corroborate the prosecution’s case.
The defense, presented by appellant and his sister CCC, argued that:

The interrogation of AAA was tainted by leading questions during the preliminary investigation.
There were alleged inconsistencies in her testimony, particularly regarding the sequence of events and her state during the assault.
It was claimed that the fact that AAA’s three younger siblings were in the same room made it highly improbable for the rape to have occurred as described.

On January 21, 2013, the trial court rendered a verdict finding appellant guilty beyond reasonable doubt of rape.
The sentence imposed was reclusion perpetua and included monetary awards: civil indemnity, moral damages, and exemplary damages.
The court gave significant weight to AAA’s testimony and her positive identification of the accused, rejecting the defense’s contention of inconsistencies.

Appellant appealed the trial court’s decision, raising issues regarding the admissibility of the questioning techniques, the credibility of AAA’s narrative, and the improbability of the incident occurring undetected by others present in the room.
The Office of the Solicitor General defended the conviction by emphasizing the consistency of AAA’s testimony with the medical findings and the corroborative statements of BBB.
The Court of Appeals affirmed the conviction with modifications:

Appellant was declared ineligible for parole.
The monetary awards were increased with the addition of interest at the legal rate of six percent per annum from the date of verdict finality.

On appeal, the only issue raised was whether the Court of Appeals erred in affirming the conviction based on the established elements of rape and the credibility of the evidence.
The appellate court and the subsequent decision reaffirmed the trial court’s findings and the credibility of AAA’s testimony, thereby dismissing the appeal.

Whether the Court of Appeals erred in affirming appellant’s conviction for rape.

Specifically, whether the established elements of rape under Article 266-A were properly identified and proven.
Whether the defense’s contention regarding the occurrence of leading questions and alleged inconsistencies in AAA’s testimony undermined the credibility of the evidence.

Whether the presence of AAA’s younger siblings in the room during the incident detracts from the plausibility of the victim’s account and consequently affects the conviction.

Whether the trial court’s fact-finding regarding witness credibility, particularly that of AAA and BBB, which was supported by medical evidence, should be given deference by the appellate court.