G.R. No. 229862 - People vs. ZZZ

The case involves a criminal prosecution for rape against accused-appellant ZZZ, who is the common-law spouse of the victim’s mother.
The incident allegedly occurred on April 12, 2006, in the City of xxxxxxxxxxx, Philippines, at approximately 11:00 a.m.
The Information charged ZZZ with having carnal knowledge of AAA, a 14-year-old minor, by means of force and intimidation, contrary to Article 266-A in relation to Article 266-B of the Revised Penal Code.

The trial court (Regional Trial Court, Bayawan City, Criminal Case No. 529) found ZZZ guilty beyond reasonable doubt of simple statutory rape despite noting that the prosecution failed to establish AAA’s minority through documentary or testimonial evidence.
The trial court gave weight to AAA’s credible and consistent testimony, as well as corroborative findings by Dr. Edalin Dacula, who conducted a medical examination revealing redness and abrasion on the victim’s labia minora.
The trial court also considered AAA’s recantation later executed through her Affidavit of Recantation and Desistance, ultimately viewing it as bolstering rather than discrediting her earlier testimony.

Testified that on the afternoon of April 12, 2006, while she was asleep after doing laundry, she was awakened to find ZZZ on top of her.
Described in detail the sequence of events including his undressing her, masturbating in her presence, forcing her to hold his penis, and eventually inserting his penis into her vagina, which caused her pain.
Later executed an affidavit in 2008 recanting her testimony, claiming duress and the influence of a certain EEE, although her recantation was treated with skepticism.

Dr. Dacula testified and presented a Medico-Legal Report indicating redness and an abrasion on the right side of AAA’s labia minora, compatible with injury caused by a smooth, soft object (identified as the accused’s penis).

BBB, AAA’s mother, testified regarding the events of the morning of April 12, 2006, including her surprise at finding AAA and ZZZ inside the house and her subsequent reaction (whipping ZZZ with a hose).
ZZZ himself testified, providing an account describing routine household activities and denying the commission of rape.
AAA also presented her recantation affidavit which, despite its inconsistencies, did not negate her earlier detailed testimony during trial.

The Regional Trial Court’s Judgment, which found ZZZ guilty and sentenced him to reclusion perpetua along with monetary awards for civil indemnity and moral damages, was appealed.
The Court of Appeals (CA) modified the trial court’s decision by deleting the word “statutory” from the conviction but affirmed the conviction based on the strength of AAA’s “vivid recollection” and the corroborative physical and circumstantial evidence.
Accused-appellant further contended, on appeal before the Supreme Court, that the prosecution failed to prove the qualifying circumstances—specifically the elements of force/intimidation and the victim’s minority—and pointed to inconsistencies in AAA’s recantation and the absence of hymenal laceration.

AAA’s recantation affidavit, executed on August 8, 2008, was scrutinized given the time lapse and circumstances under which it was made.
The recantation was deemed unreliable as an indication of actual duress, especially in light of her earlier candid testimony and the fact that she was not coerced or forced during her trial testimony.

Whether the prosecution has established beyond reasonable doubt that accused-appellant ZZZ committed rape against AAA.
Whether the evidence, including the victim’s detailed testimony and medical findings, were sufficient to support the conviction despite the inconsistencies raised by AAA’s subsequent recantation.

Whether the prosecution proved the presence of force, threat, intimidation, fraud, or grave abuse of authority in the commission of the crime.
Whether AAA’s age and the implications regarding statutory rape versus simple rape were correctly addressed given that the Information stated she was 14, despite the trial court’s erroneous use of the term “statutory.”

How the credibility of AAA was evaluated, considering her initial testimony, the corroborative evidence provided by Dr. Dacula, and her later recantation.
Whether the demeanor and detailed recollection of AAA during trial was sufficient to outweigh the later affidavit of recantation.