G.R. No. 241787 - People vs. XXX

This case is an appeal from decisions rendered by the Regional Trial Court (RTC) and the Court of Appeals (CA) in criminal cases involving the accused-appellant, X X X, for two counts of qualified rape.
The alleged crimes occurred in or about May 2007, involving the minor victim AAA, who was approximately nine (9) years old at the time.
The matter was prosecuted under the charge that the accused, being the biological father of the victim, committed rape—an act qualified by the special circumstance of his relationship with her.

The pivotal evidence consisted of the detailed, candid, and unambiguous testimonial account of the victim, AAA.

AAA stated that her father forcibly raped her twice, using threats (e.g., “If you report, I will kill you”) to coerce compliance.
Her testimony detailed the removal of her clothing, the physical act of rape, and her subsequent feelings of pain and fear.

Supplementary evidence included a medico-legal report, which, although not directly identified by its examining physician in court, was referenced as corroborative.
The documentary evidence was also crucial: certificates of live birth and marriage were introduced to establish both the victim’s minority and her filiation with the accused.

The victim, AAA, was not in his custody during the time of the alleged incidents, but rather with his mother-in-law, BBB.
The case was allegedly instigated by BBB, purportedly out of jealousy and with the motive to create discord between him and his wife, CCC, who was sending him remittances.

The defense argued that the trial court erred in relying on what it described as the “incredible testimony” of the private complainant and in admitting the medico-legal report without direct identification by the examining physician.

Two separate criminal cases (BR. 20-7306 and BR. 20-7307) were instituted against the accused-appellant for qualified rape.
At trial, the RTC found the accused guilty beyond reasonable doubt and imposed the penalty of reclusion perpetua per count, along with civil, moral, and exemplary damage awards.
On appeal, the CA modified the RTC’s decision by increasing the monetary awards and reaffirmed the conviction based on the consistent, credible, and detailed account of the victim.
Both the accused-appellant and the Office of the Solicitor General (OSG) opted not to submit supplemental briefs, thereby effectively adopting their earlier positions.

Whether the trial court and the appellate court erred in relying on the victim’s testimony by deeming it credible and categorically reliable, despite the defense’s claim of its incredibility.

Whether the admission of the medico-legal report in evidence, notwithstanding the fact that the examining physician did not identify the report in court, constitutes reversible error.

Whether the trial court erred in completely disregarding the accused-appellant’s defense of denial, which questioned his custodial relationship with the victim during the period in question.