G.R. No. 231386 - People vs. XXX

Three separate Informations were filed against accused-appellant XXX for the rape of his daughter, AAA.
Each Information detailed distinct incidents:

Criminal Case No. 00-2601(M) alleged that in or about June 1995 in Barangay [DDD], Apalit, Pampanga, XXX carried his 13-year-old daughter from the sleeping area, undressed both of them, kissed her, and inserted his penis into her vagina using force, threat, and intimidation.
Criminal Case No. 00-2602(M) purported that in or about October 1999, in the same barangay and municipality, he similarly carried his 17-year-old daughter while she was sleeping with her mother, removed her panty, and committed the act with similar forceful measures.
Criminal Case No. 00-2603(M) recounted a series of incidents between June 1995 and October 1999 in which the accused repeatedly carried out carnal knowledge with his daughter, a minor, employing the same modus operandi—force, threat, and intimidation.

AAA’s testimony was detailed and consistent, recounting how on various nights the accused assaulted her even as other family members slept in the same room.
The victim described being carried aside, undressed, kissed, and physically overpowered by her father.
Medical evidence supported the victim’s allegations:

A medical examination in January 2000 confirmed that she was “2-3 months pregnant.”
Subsequent miscarriage reinforced the timeline and physical consequences of the alleged abuse.

Accused-appellant firmly denied the allegations, asserting that no such incidents occurred.
His testimony focused on a claimed “misunderstanding” with his daughter regarding her 18th birthday, wherein her disappointment over not receiving a cotillion or debut party allegedly led her to falsely accuse him of rape.
Throughout cross-examination, the accused remained noncommittal and provided evasive responses when directly asked about the sequence of events detailed by the victim.

At the Regional Trial Court (RTC) in Macabebe, Pampanga, the victim's testimony was deemed clear, convincing, and free from material contradiction.
The RTC found that the elements of rape—carnal knowledge achieved through force or intimidation—were present in the separately alleged incidents.
Based on the evidentiary record, the RTC convicted the accused on:

Two counts of Qualified Rape (Criminal Cases No. 00-2601(M) and 00-2602(M)).
One count of Simple Rape (Criminal Case No. 00-2603(M)) because the information did not specify the victim’s age between 12 and 17 despite her status as a minor.

Accused-appellant filed an ordinary appeal challenging the RTC decision.
The Court of Appeals (CA) affirmed the RTC’s findings but modified the amount of damages awarded to AAA, increasing them to One Hundred Thousand Pesos for each category per count in the qualified rape cases.
The CA emphasized that the victim’s testimony, supported by physical and circumstantial evidence, sufficiently established the elements of the crime.

Whether the RTC and the CA erred in convicting accused-appellant for two counts of Qualified Rape and one count of Simple Rape.

The sufficiency and credibility of the victim’s testimony as the sole, but clear and convincing, evidence establishing the commission of the crimes.
The propriety of relying on a series of incidents, especially in light of the accused-appellant’s defense based solely on denial and a claimed misunderstanding.
Whether the approximated dates in Criminal Case No. 00-2603(M)’s Information—spanning several years—compromised the accused’s constitutional right to be informed of the exact nature of the charges.
The adequacy of the Information in fairly preparing the accused’s defense given the broad time frame detailed therein.