G.R. No. 167390 - Spouses Ferdez vs. Spouses Co

The case is an ordinary appeal assailing the Court of Appeals’ Decision dated June 29, 2018.
The CA Decision modified and affirmed the Regional Trial Court’s Decision dated May 9, 2017.
The RTC, in Criminal Case No. 616-M-2014, found accused-appellant XYZ guilty beyond reasonable doubt of Rape under paragraph 1(a), Article 266-A of the Revised Penal Code, as amended by RA 8353, while acquitting him in Criminal Case Nos. 617-M-2014 and 618-M-2014.
The accused-appellant raised various issues in his appeal, adopting arguments from his Appellant’s Brief, while the Office of the Solicitor General (OSG) adopted the Brief for the Plaintiff-Appellee.

The case arose from three separate Informations charging XYZ with three counts of Rape, specifically:

Criminal Case No. 616-M-2014 – on December 23, 2013, involving the forcible insertion of XYZ’s penis into the vagina of AAA, a 15-year-old minor, using force, violence, and intimidation.
Criminal Case No. 617-M-2014 – on January 3, 2014, wherein XYZ allegedly inserted his finger into AAA’s vagina while she was asleep, employing force and intimidation.
Criminal Case No. 618-M-2014 – on January 16, 2014, a repetition of the sexual assault by forced finger insertion while AAA was asleep.

Testimony of the victim, AAA, was central to the prosecution’s case, providing details of how the accused approached her, used threats (including the threat to evict her family), and committed the acts.
The accused-appellant presented an alibi for each incident, claiming he was engaged in activities away from the scene (mending fishing nets or being at his mother’s house) during the alleged times.
The prosecution maintained that despite minor inconsistencies in the victim’s accounts, her overall testimony was credible and sufficient to establish the elements of rape in Criminal Case No. 616-M-2014.

During trial, the RTC found that AAA’s testimony regarding the December 23, 2013 incident was consistent and credible, leading to a conviction on that count.
The RTC ruled that the elements of force, violence, and intimidation were not satisfactorily proven for the January 3, 2014 and January 16, 2014 incidents, resulting in acquittals on those counts.
The CA upheld the RTC’s findings but modified the award for civil indemnity, moral damages, and exemplary damages by increasing them and imposing interest.
The accused-appellant questioned the credibility of AAA’s testimony, citing discrepancies in her statement and inconsistencies with her earlier sworn affidavit, while the prosecution and OSG argued that minor lapses do not detract from the veracity of the victim’s account.

Whether the Court of Appeals correctly affirmed the conviction of accused-appellant for Rape in Criminal Case No. 616-M-2014 despite the alleged inconsistencies in the victim’s testimony.
Whether the evidentiary findings and credibility assessments conducted by the trial court should be disturbed by the appellate court.
Whether the defense’s alibi and denial, based solely on self-serving assertions and unsupported by independent evidence, are sufficient to overturn the victim’s testimony.