G.R. No. 230981 - People vs. XXX

The accused-appellant was the common-law husband of AAA’s mother, living with her and her half-siblings in Misamis Oriental.
AAA, the victim, grew up in the same household and affectionately called the accused-appellant “Papa XXX.”

In Criminal Case No. 2011-440 for sexually abusing his 12-year-old step-daughter under violations of Section 5(b) of RA 7610 (Child Abuse).
In Criminal Case No. 2011-441 for rape under Article 266-A, in relation to Article 266-B of the RPC.

Insertion of his penis into AAA’s vagina while she was 12 years old.
Repeated molestation on subsequent days (including forced oral sex).
Additional incident at age 13 involving anal penetration and manipulative “picking” of her vagina, both in the confines of the family residence and at a pigpen near the house.

AAA provided a clear and detailed account of her ordeal, recounting multiple instances where the accused-appellant abused her.
She testified on how the abuse occurred in their home when her mother was away selling rice cakes and when accompanied by her siblings.
Her testimony was emotional, including moments of sobbing and vivid descriptions of the abuse.

Medical evidence presented by Dr. Masorong confirmed old and healed hymenal lacerations at the 5 and 9 o’clock positions.
Psychologist Villanueva testified that AAA suffered from an anxiety disorder and exhibited symptoms typical of a sexually abused minor.
Additional witnesses, including police personnel, corroborated details regarding the scene and circumstances.

The accused-appellant denied the allegations, asserting that any physical actions taken were disciplinary in nature following AAA’s alleged misbehavior (stealing items).
AAA’s mother (BBB) corroborated part of his account by stating that disciplinary measures were meted out; however, her testimony did not support the occurrence of sexual abuse.
CCC, another family member, confirmed her presence in the household but did not witness any abuse.

At trial before the RTC, the prosecution successfully discharged its burden by relying primarily on AAA’s credible and steadfast testimony as well as supporting medical and psychological evidence.
The RTC issued a joint decision finding the accused-appellant guilty beyond reasonable doubt on both charges with corresponding penalties and damages.
The Court of Appeals (CA) later affirmed the RTC’s ruling in its Decision dated October 27, 2016, dismissing the accused’s appeal and upholding the credibility of the victim’s testimony and the evidentiary findings.

AAA recounted in detail the moments when the accused-appellant removed her clothing and forcibly performed acts of sexual intercourse (both vaginal and anal) and oral sex.
She described threats made by the accused-appellant, including explicit warnings that escalated her fear and prevented her from reporting the abuse immediately.
The medical report and the Living Case Report provided forensic evidence which was consistent with her description of the events.

Whether the victim’s testimony, along with corroborative medical and psychological evidence, established the elements of rape and child abuse beyond reasonable doubt.
Whether the temporal sequence of events and the physical findings sufficiently corroborated AAA’s account of repeated abuse.

Whether the victim’s failure to immediately report the abuse undermined the credibility of her testimony.
Whether the behavioral response of a minor to traumatic abuse could be reasonably expected to follow a “standard” or rational pattern.

Whether the accused-appellant’s actions met the criterial elements of qualified rape under Article 266-A (in relation to Article 266-B) and lascivious conduct under Section 5(b) of RA 7610.
Whether the defense’s reliance on denial and the claim of disciplinary action could overcome the weight of evidence presented.

Whether the reclassification or modification (nomenclature) of the offense based on the victim’s age and the relationship between the parties was justified.
Whether the appropriate penalties, including reclusion perpetua and the award of damages, were correctly imposed in light of existing jurisprudence and statutes.