G.R. No. 244047 - People vs. XXX

The case involves the People of the Philippines as plaintiff-appellee and XXX as accused-appellant.
Accused-appellant was charged with qualified statutory rape under paragraph 1(d) of Article 266-A, in relation to Article 266-B of the Revised Penal Code (RPC), as amended by Republic Act No. 8353.
The incident occurred on or about the evening of January 2, 2013, and early in the morning of January 3, 2013, in Brgy. Cayanga, San Fabian, Pangasinan.
The victim, identified as AAA, was a 5-year-old minor (born June 6, 2007).

The identities of the parties involved.
The victim’s birthdate and minority status.
The report of the incident to the Philippine National Police, San Fabian, Pangasinan.
The existence of a Medico-Legal Report issued by a medical officer from Region I Medical Center.

The prosecution presented the victim (AAA), her mother, and Police Officer 2 Irene Robosa as witnesses.
The victim, despite her tender age, testified under oath that:

She stated plainly that the accused “placed his penis inside [her] vagina.”
She identified the accused in open court and pointed him out.
Her account was corroborated by her subsequent physical discomfort and observations by her mother.

Accused-appellant was her long-time live-in partner.
On the day of the incident, after leaving the home briefly, she discovered her daughter crying and complaining of vaginal pain.
Upon inspection, she noted the redness of the victim’s vagina and confronted the accused, who allegedly admitted to “playing with the vagina.”

PO2 Robosa testified as the officer on duty when the incident was reported and relayed that during the incident report the accused-appellant admitted involvement.
The defense offered the sole testimony of accused-appellant who:

Acknowledged his relationship as the live-in partner of the victim’s mother.
Denied the rape charge, attributing the report of the incident to an alleged extortion attempt linked to a labor case.

Medical evidence from the medico-legal report supported the victim’s testimony by documenting:

The Regional Trial Court (RTC) convicted accused-appellant of qualified rape and sentenced him to reclusion perpetua, along with ordering him to pay civil indemnity, moral damages, and exemplary damages.
On appeal, the Court of Appeals (CA) affirmed the RTC’s ruling while modifying the monetary awards to PhP100,000 each for civil indemnity, moral damages, and exemplary damages, with interest imposed at 6% per annum.
Accused-appellant filed an appeal questioning the credibility of the child victim’s testimony and emphasizing alleged inconsistencies.
The appeal centered on whether the positive identification and the detailed account provided by the minor were tainted by coaching or inconsistencies.

Whether the trial court properly established beyond reasonable doubt that the accused-appellant committed qualified statutory rape by proving:

Whether the alleged inconsistencies in the child victim’s testimony were sufficient to undermine her credibility.
Whether the appellate courts were justified in upholding the findings of the lower courts given the evidence presented.