Case Digest (G.R. No. 233867)
Facts:
People of the Philippines v. XXX, G.R. No. 233867, February 28, 2022, the Supreme Court Second Division, Hernando, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is identified by the initials XXX pursuant to administrative circulars protecting the identity of child-victims.The criminal case began with three separate Informations accusing XXX of two counts of Rape through sexual assault (paragraph 2, Article 266‑A, Revised Penal Code, as amended by Republic Act No. 8353) and one count of Rape through sexual intercourse (paragraph 1, Article 266‑A) — each charged in relation to Republic Act No. 7610 — for acts allegedly committed against a 14‑year‑old girl (identified as AAA) on August 23, 2006 (Crim. Case No. 07‑146), August 26, 2006 (Crim. Case No. 07‑147), and September 2, 2006 (Crim. Case No. 06‑809). XXX pleaded not guilty; the three matters were consolidated for trial in the Regional Trial Court (RTC), Branch 207.
At trial the victim AAA testified in detail about three nocturnal intrusions by accused XXX (a stay‑in family driver) during which he covered her mouth, kissed and groped her, inserted fingers into her vagina on two occasions, and had sexual intercourse with her on one occasion, each time threatening to kill her or her family should she report the incidents. A housemaid (CCC) corroborated that the accused was found in the girls’ room at one of the incidents. A medico‑legal examination by Police Senior Inspector Marianne Ebdane disclosed healed lacerations at the five and seven o’clock positions of AAA’s hymen, described as evidence of blunt penetrating trauma.
The RTC, in a November 5, 2014 Joint Decision, found XXX guilty beyond reasonable doubt on all three charges, giving weight to AAA’s testimony and CCC’s presence in the room and rejecting XXX’s denials and the asthma‑check explanation. XXX appealed to the Court of Appeals (CA), which, in CA‑G.R. CR‑H.C. No. 07147, promulgated March 30, 2017, affirmed the RTC’s convictions but modified the amounts of civil indemnities, damages, and fines. The CA held that AAA’s testimony was credible and sufficiently corroborated by the medico‑legal findings and that failure to present other household members was not fatal.
Still aggrieved, XXX elevated the case to the Supreme Cour...(Pro-only)
Issues:
- Was the conviction of accused‑appellant XXX on the three sexual‑offense charges proper? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)