Case Digest (G.R. No. 244255)
Facts:
The People of the Philippines charged XYZ by two Informations alleging he raped his daughter on November 20, 2009 and December 22, 2011 at [CCC], Province of Sorsogon; arraignment was on May 18, 2012, and the RTC convicted him and sentenced him to reclusion perpetua on April 28, 2017. The Court of Appeals affirmed with modification on May 31, 2018, finding him guilty of two counts of qualified rape, and the Supreme Court resolved the appeal by decision dated August 26, 2020.
The prosecution relied on the victim’s categorical testimony and the medico-legal report of Dr. Salve B. Sapinoso showing healed hymenal lacerations; the defense presented the accused’s denial, an alibi placing him three kilometers away, and a denial of biological parentage of the victim.
Issues:
- Whether the victim’s testimony and medical evidence sufficed to sustain conviction.
- Whether the accused’s alibi and denial warranted acquittal.
- Whether the crime may be qualified as qualified rape given the allegations in the Informations.
Ruling:
The appeal lacked merit and was dismissed; the Court affirmed with modification the CA decision insofar as it convicted XYZ of two counts of rape but reversed the CA’s qualification of the offense. The Court found XYZ guilty of two counts of rape (one statutory rape under Article 266-A, paragraph 1(d) and one rape under Article 266-A, paragraph 1(a)), imposed reclusion perpetua for each count, and ordered payment of P75,000.00 civil indemnity, P75,000.00 moral damages, and P75,000.00 exemplary damages for each count, with six percent interest from finality.
Ratio:
The Court gave weight to the victim’s categorical, spontaneous, and corroborated testimony and to the medico-legal findings, noting that such testimony, when supported by medical evidence, establishes unlawful carnal knowledge beyond reasonable doubt. The accused’s alibi failed because he did not prove physical impossibility—the alleged three-kilometre distance was insufficient and uncorroborated—and positive identification by the victim prevails over an unsubstantiated alibi.
The Court held that qualified rape requires the qualifying filial relationship to be specifically alleged in the Information and proved beyond reasonable doubt under Rule 110, Sections 8 and 9; the Informations here alleged the accused as the “natural father,” but the victim made a judicial admission that he was not her biological father and no marriage certificate was offered to prove step-parentage, so the qualifying circumstance of relationship was neither properly pleaded nor proven.
Doctrine:
- The Information must allege all elements of the crime and the proper qualifying or aggravating circumstances that change the nature of the offense.
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