G.R. No. 257276 - People vs. XXX

The case involves People of the Philippines versus accused-appellant XXX, who was charged with Qualified Rape.
The appeal was filed by accused-appellant challenging the November 25, 2020 Decision of the Court of Appeals (CA) which modified the original charge rendered by the Regional Trial Court (RTC).
The RTC, Branch 7 of xxxxxxxxxxx, convicted the accused on February 20, 2019 for Qualified Rape and imposed penalties including reclusion perpetua without eligibility for parole and monetary damages.

The incident occurred on or about August 8, 2009, within the jurisdiction of the court in a location redacted pursuant to administrative orders.
Accused-appellant, the uncle of the victim (AAA), was alleged to have willfully committed acts of rape against the 7-year-old victim.
The Information charged him with Qualified Rape, aggravated by relationship, as he is described as the brother of the victim’s father.

Complainant AAA’s temporary medical certificate, birth certificate, and baptismal certificate were admitted to establish her age and identity.
The authenticity and due execution of the temporary medical and final medico-legal reports were admitted by the defense.

AAA testified in detail about how the accused-appellant summoned her, undressed himself, proceeded to kiss her, and eventually subjected her to sexual intercourse (both vaginal and forced oral sex under threat).
BBB, the victim’s mother, corroborated the account by recounting her discovery of the incident through visual evidence when passing by the accused’s window and later rushing to her daughter.
Medical evidence was presented by Dr. Florence J. Curbilla, who found physical signs (an abrasion on the labia majora and an old healed incomplete hymenal laceration) that supported the testimony.

The stenographic notes of several witnesses were lost due to Typhoon Yolanda, leading to the retaking of testimonies (except for Dr. Gler’s).
Despite these challenges, the testimonies provided by AAA and BBB were deemed clear, consistent, and credible.

The accused-appellant denied committing the rape, claiming he was asleep in his house at the time of the incident.
He argued that the testimonies of AAA and BBB contained glaring inconsistencies and questioned the veracity of BBB’s delayed intervention.
He maintained that no substantial evidence was presented to prove his relationship to the victim, asserting that a land dispute was the probable motive behind the complaint.

The RTC convicted the accused, primarily basing its decision on the straightforward and affirmative testimonies of the victim and her mother which were corroborated by the medico-legal findings and documentary evidence.
The RTC found proved that the victim was 7 years old at the time of the incident and that a qualifying relationship existed between the accused-appellant and the victim.

The CA modified the crime from Qualified Rape to Statutory Rape, noting that while the prosecution sufficiently established the elements of statutory rape, the allegation on relationship was found insufficient under prevailing jurisprudence.
The CA affirmed the conviction and adjusted the monetary awards, reducing them compared to the RTC’s award.

Whether the combined testimonials of AAA and BBB, along with the medico-legal and documentary evidence, were sufficient to establish the commission of rape beyond reasonable doubt.
Whether the victim’s age and the physical evidence conclusively supported the charge despite the loss of initial stenographic records.

If the victim’s straightforward, consistent, and unshaken testimony during cross-examination should be given the highest probative value in a rape case.
Whether the denial by the accused-appellant, which relied on self-serving negative evidence, could overcome the affirmative declarations of the victim and her mother.

Whether the allegation of relationship, as stated in the Information (i.e., accused being the uncle of the victim by being the brother of her father), sufficiently satisfied the special qualifying circumstance required for a charge of Qualified Rape under prevailing jurisprudence.
The implications of not specifically alleging that the relationship was “within the third civil degree” and if such omission still conforms with established legal standards as seen in previous cases.

Whether the appellate court should defer to the trial court’s assessment of witness credibility unless there is clear evidence of arbitrariness or oversight.
The extent to which the appellate court may re-evaluate the factual findings especially on testimony in rape cases.