G.R. No. 137378 - Philippine Aluminum Wheels, Inc. vs. FASGI Enterprises, Inc.

The case involves the accused-appellant XXX charged with three sexual offenses consolidated into a single trial:

The offenses were consolidated by the Regional Trial Court (RTC) in its November 5, 2014 Joint Decision, later modified and affirmed by the Court of Appeals (CA) in its March 30, 2017 Decision, and subsequently elevated to the Supreme Court on appeal.
The charges were assessed under Article 266-A of the Revised Penal Code (RPC) as amended by Republic Act (RA) 8353, in relation to RA 7610, which provides special protection for children.

Occurred in the residence where the accused was employed as a stay-in family driver.
The victim, AAA (a 14-year-old minor), testified that while she was asleep, the accused entered her room, covered her mouth, and initiated unwanted physical contact by kissing her neck and lips.
He then proceeded to insert his finger into her vagina, using his physical strength to subdue her and threatened her by stating that he would kill her and her family if she disclosed the incident.
AAA later woke her younger sister, BBB, but did not report the incident out of fear of the threats made.

Also occurred in the early morning at the same residence.
AAA testified that the accused again entered her room, covered her mouth, and this time removed her jogging pants and underwear.
He then forcibly inserted his penis into her vagina for about five to ten minutes.
Throughout the incident, he employed the same threat of killing her and her family, compelling her silence.
After the assault, AAA again woke her sister, BBB so that she could wash up, yet she remained silent about the occurrence.

Occurred during the early hours of the morning when AAA was in her room.
The accused entered and locked the door, further suggesting premeditation.
AAA reported that the accused kissed her and proceeded to insert his finger into her vagina once more.
During this incident, CCC, a nursemaid in the household, discovered unusual circumstances; she found the door locked, observed the accused’s presence briefly when he was seen sitting near BBB’s bed, and later questioned his actions.

AAA provided detailed accounts of all three incidents during direct examinations in court, clearly describing the physical acts, the use of force, and the specific threats uttered by the accused.
Her testimony was consistent across all incidents and was deemed credible by the trial court.

CCC, the household nursemaid, corroborated details regarding the accused’s presence in the victim’s room during the third incident.
A medical examination performed by Police Senior Inspector Marianne Ebdane revealed deep healed lacerations on AAA’s hymen at the crucial five and seven o’clock positions, indicating clear evidence of blunt penetrating trauma.

The accused-appellant denied involvement in the incidents on August 23 and August 26, claiming he was asleep in his quarters at the time.
For the incident on September 2, although he admitted being present in the room, he denied molesting AAA and contended that he had returned solely to check on her condition after an asthma attack the previous night.
His explanations regarding his physical presence and actions were found unconvincing when weighed against the victim’s testimony and the corroborative evidence.

The offenses were charged under Article 266-A of the RPC, which defines rape through two different modes:

Rape through sexual intercourse (involving carnal knowledge)
Rape through sexual assault (involving the insertion of an object or part of the body into the genital or anal orifice)

Given that AAA was a 14-year-old minor, the provisions of RA 7610 were also engaged, necessitating the reclassification of the charges in terms of “Lascivious Conduct under Section 5(b) of RA 7610” for the incidents involving sexual assault.

Whether the conviction of accused-appellant XXX on all charges—two counts of rape through sexual assault and one count of rape through sexual intercourse—is proper and supported by evidence.

Whether the victim’s (AAA’s) testimony, despite the absence of corroborative testimonies from her sister or parents, is sufficiently credible and reliable to sustain the conviction.
The weight to be accorded to the medical evidence, particularly the findings of deep healed lacerations on the hymen, in corroborating AAA’s testimony.
The credibility of the accused-appellant’s defense, which rests largely on his claims of non-presence during two incidents and on a purported benign explanation (monitoring a supposed asthma attack) during the third incident.
Whether the behavioral expectations of a rape victim, including the timing of reporting the incident, should affect the evaluation of testimony.
The proper application and interpretation of the statutory provisions under Article 266-A of the RPC, RA 8353, and RA 7610 in reclassifying the offense and determining the penalties.