G.R. No. 232500 - People vs. ZZZ

The accused-appellant ZZZ was charged in six separate Informations for multiple offenses, including violations of Section 5(a) and (i) in relation to Section 6(a) and (f) of R.A. No. 9262 (the Anti-Violence Against Women and Their Children Act), rape, and three counts of acts of lasciviousness in relation to R.A. No. 7610.
The case consolidated criminal charges arising from incidents that allegedly occurred over a span of several years and in different contexts, involving his minor children and his twelve (12)-year-old son AAA.
The charges arose from factual allegations of psychological, emotional, and physical abuse, including instances of verbal berating, boxing, physical assault, and multiple acts of sexual abuse by a father against his minor daughters.

Accused-appellant was accused of inflicting emotional and psychological violence on his twelve (12)-year-old son AAA by verbally abusing him and physically assaulting him (boxing resulting in a bleeding mouth and loosened teeth).
Witnesses, including AAA’s mother DDD and his sister EEE, corroborated that a physical assault occurred which caused both physical injury and mental anguish, humiliation, and ridicule.

The accused-appellant was alleged to have taken his then ten (10)-year-old daughter BBB to an irrigation area, compelled her to lie upon a banana leaf, removed her lower garment, and forcibly inserted his penis into her vagina.
BBB, despite her young age, provided a detailed narrative of the incident, admitting fear and compliance due to her father’s authority and cruelty.
There was a discrepancy in the alleged age stated in the Information (sixteen [16] years old) versus her birth certificate (indicating she was ten [10] years old), though the prosecution proved her minority at the time of the offense.

Accused-appellant was charged with acts of lasciviousness committed against his fourteen (14)-year-old daughter CCC.
The incidents involved the accused-appellant embracing, fondling, and touching CCC’s breasts and sexual parts on different occasions, all allegedly performed by taking advantage of his moral ascendancy as her father.
CCC provided a detailed testimony including her feelings of fear, resistance, and subsequent distress as a result of the sexual abuse.

Accused-appellant admitted having fourteen children and claimed a close relationship with some of his offspring; however, he denied the allegations of abuse, attributing the accusations to inter-family conflicts.
During trial, testimonies from both child victims and other family members established a pattern of repeated abusive conduct over the years.

The Regional Trial Court (RTC) of Calapan, Oriental Mindoro, Branch 39, rendered a Joint Decision on October 29, 2013, finding ZZZ guilty beyond reasonable doubt on all counts, and imposing varying penalties including reclusion perpetua, prision mayor, and arresto mayor, with corresponding fines and damages.
The Court of Appeals (CA) affirmed the RTC’s decision with certain modifications, such as adjusting the monetary awards and confirming the imposition of mandatory psychological counseling for the accused-appellant.
The case reached the Supreme Court on appeal where the petition was eventually denied, and the judgments of the RTC and CA were affirmed—with modifications on the qualifications of the crimes in the lascivious conduct cases (changing the nomenclature and adjusting penalties).

AAA testified regarding the physical and emotional abuse he suffered when his father berated and assaulted him.
BBB gave a detailed account of the rape incident, including a question-and-answer session that revealed her fear, pain, and reluctant compliance.
CCC recounted the lascivious acts committed against her and the subsequent trauma experienced.

The prosecution relied on documentary evidence (such as medical certificates and birth certificates) and witness testimonies to corroborate the abuse and to establish the victim’s minority and the relationship with the accused.

Whether the testimonies of the child victims and other cooperating witnesses, despite potential familial animosity, were sufficient and credible to withstand the accused-appellant’s argument of ill will influencing their statements.
The weight accorded to the direct observations and behavior of the witnesses during testimony, particularly in cases involving sensitive issues of rape and sexual abuse.

Whether the original charges of rape and acts of lasciviousness should be modified to qualified rape and lascivious conduct under Section 5(b) of R.A. No. 7610 based on the relationship between the accused and his minor victims.
The appropriateness of upgrading certain charges (e.g., converting the rape charge against BBB to qualified rape) given the aggravating circumstance of the father–daughter relationship.
The correct application of the respective penalties provided by R.A. No. 9262 and R.A. No. 7610, including the mandatory imposition of psychological counseling in addition to imprisonment and fines.

Whether proper notice was given, particularly in light of the discrepancy in the alleged age of BBB, so as to not deprive the accused of his right to be informed of the specific charge against him.
Whether all elements of the crimes charged, such as physical violence, emotional abuse, and acts amounting to sexual abuse, were adequately proven beyond reasonable doubt.

The determination of the appropriate range for the indeterminate penalties imposed, including the application of the Indeterminate Sentence Law in determining minimum and maximum periods for prision correccional and prision mayor.
The decision to require mandatory psychological counseling or psychiatric treatment as an ancillary penalty under R.A. No. 9262.