Title
People vs. XXX
Case
G.R. No. 255491
Decision Date
Apr 18, 2022
Father convicted of raping minor daughter on multiple occasions; Supreme Court upheld conviction based on credible testimony, minority of victim, and qualifying father-daughter relationship.

Case Digest (G.R. No. 255491)
Expanded Legal Reasoning Model

Facts:

  • Overview of the Case
    • Accused-appellant XXX was charged with Qualified Statutory Rape for allegedly having carnal knowledge of his minor daughter, AAA, on three separate occasions.
    • The charges were filed through three separate Informations covering the incidents allegedly occurring in 2004, 2005, and 2007.
    • The case involves the application of Articles 266-A and 266-B of the Revised Penal Code, as amended by Republic Act No. 8353, with the qualifying circumstance being the father-daughter relationship.
  • Alleged Criminal Acts
    • Criminal Case No. 33-09 (Incident on March 13, 2007)
      • Accused-appellant, motivated by lust, allegedly used force, threats, and intimidation against his 11-year-old daughter, AAA (born May 14, 1995), by inserting his penis into her vagina against her will.
      • The incident allegedly took place in a private residence, where the accused-appellant escalated the act by ordering AAA to change clothes and lie on the floor before committing the act.
    • Criminal Case No. 34-09 (Incident around 2004)
      • The Information charged that the accused-appellant, with similar intent and methods, committed the rape when AAA was 9 years old.
      • The act was described with the same elements of force, threat, and abuse of moral authority.
    • Criminal Case No. 35-09 (Incident around 2005)
      • The allegation centers on the accused-appellant committing the same crime when AAA was 10 years old.
      • The modus operandi and the application of force and intimidation mirror those in the other counts.
  • Prosecution’s Evidence and Testimonies
    • Testimony of Victim AAA
      • AAA’s account was described as straightforward, categorical, and spontaneous during direct and cross-examination.
      • She identified accused-appellant as the perpetrator and recounted the details of the assault on all three occasions.
    • Corroborative Evidence
      • The testimony of other witnesses, including BBB (mother of the victim) and CCC (AAA’s brother), provided an account of the circumstances surrounding the incident.
      • Medical evidence presented by Medico-Legal Officer Marianne S. Ebdane noted that while no lacerations were found, such findings could not exclude the possibility of sexual abuse, especially given the victim’s age.
    • Documentary and Physical Evidence
      • AAA’s Certificate of Live Birth confirmed her age, establishing that she was below twelve during the alleged incidents.
      • The medical report, though declared corroborative and dispensable by the trial court, was discussed to highlight that physical signs of injury are not mandatory for the proof of rape.
  • Defense’s Version and Arguments
    • Accused-appellant’s Alibi and Denials
      • The defense claimed that accused-appellant was engaged in activities away from the residence during the time of the alleged incident.
      • A detailed timeline was presented by the defense, stating that the accused-appellant was with other family members and later at a seaside or with a live-in partner during the hours in question.
    • Contentions Regarding Testimonial Inconsistencies
      • The defense argued that the victim’s testimony was inconsistent, noting a discrepancy where AAA stated that her mother learned of the incident through her brother, yet also claimed her brother did not actually witness it.
      • The accused-appellant further contended that the victim’s narrative sounded memorized and rehearsed.
    • Critique of Physical Evidence
      • The defense asserted that the medical findings reported by Officer Ebdane were contrary to AAA’s account of the incident, leveraging the absence of laceration or visible injury as a basis for their argument.
      • These defenses were ultimately maintained as mere allegations without corroborative evidence.
  • Chronology of Proceedings
    • Trial Court Decision (August 9, 2017)
      • The Regional Trial Court found the accused-appellant guilty beyond reasonable doubt on all three counts of Qualified Statutory Rape.
      • The conviction was based primarily on the credibility of AAA’s testimony, supplemented by circumstantial and documentary evidence.
      • The Court imposed reclusion perpetua without benefit of parole and ordered substantial monetary awards as civil indemnity, moral, and exemplary damages.
    • Court of Appeals Decision (September 27, 2019)
      • The Court of Appeals affirmed the trial court’s findings and convicted the accused-appellant for all three counts.
      • It increased the amounts for civil indemnity, moral, and exemplary damages to P100,000 each for every count.
    • Supreme Court Appeal
      • The accused-appellant appealed the CA decision, contending inconsistencies and alleging that the physical evidence did not substantiate the charges.
      • The People, through the Office of the Solicitor General, supported the CA finding and reiterated the primacy of witness credibility.

Issues:

  • Whether or not the evidence presented at trial proves beyond reasonable doubt that accused-appellant committed Qualified Statutory Rape on three separate occasions.
    • Whether the testimony of the victim, AAA, is sufficiently credible and consistent despite minor discrepancies.
    • Whether the absence of visible injuries in the medico-legal report undermines the prosecution’s case.
    • The weight to be accorded to the trial court’s factual findings regarding the credibility of witnesses.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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