G.R. No. 193893-94 - Land Bank of the Philippines vs. Megaworld Corp.

The accused-appellant, ZZZ, was charged with Qualified Rape under Article 266-A, paragraph 1(a) of the Revised Penal Code (RPC) and violation of Section 5(b), Article III of Republic Act No. 7610, alleging acts of rape and child abuse.
The charges stem from two separate incidents involving the victim AAA, who is ZZZ’s biological daughter, committed on November 28, 2016 and December 12, 2016.
At the time of the incidents, AAA was fourteen (14) years old and resided in the same house with ZZZ, her mother YYY, and her sibling BBB.

AAA testified that around 5:00 p.m. while she was taking a nap in her room, ZZZ unexpectedly entered.
ZZZ removed her pants and underwear, fondled and licked her vagina, and then inserted his penis into her vagina making several push and pull motions.
After the act, ZZZ threatened AAA by warning that if she disclosed the incident, he would be sent to jail and she and her siblings would be left uncared for.
AAA noted that she did not call out for help because ZZZ had a scythe nearby.

AAA and her nine-year-old sibling, BBB, were sleeping when ZZZ entered their room.
ZZZ fondled and sucked AAA’s breasts; later, he again inserted his penis into her vagina and made several push and pull motions.
After the act, ZZZ left the room after threatening to kill them all if she told anyone, emphasizing the potential harm to her sister BBB if she resisted.

AAA’s younger sister, BBB, provided testimony regarding the living arrangements and questioned the appropriateness of ZZZ’s behavior, which led to AAA’s disclosure to her mother, YYY.
AAA underwent a medical examination on January 31, 2017, which revealed partially and completely healed lacerated wounds in positions consistent with sexual abuse.
A Social Case Study Report further corroborated AAA’s account of the alleged rape and abuse on both incident dates.
During pre-trial, parties stipulated that AAA is the biological daughter of ZZZ and YYY, and that she was fourteen (14) years of age during the commission of the crimes.

For the November 28 incident, he claimed that he was in the same room as his eldest daughter, her husband, and their two minor children, asserting no unusual behavior occurred.
For the December 12 incident, he stated that he and AAA, along with BBB and his two sons, were at a neighbor’s house watching television, later reprimanding AAA for using her phone, and then sleeping on their mats.

ZZZ questioned the credibility of AAA’s testimony by citing alleged discrepancies between her affidavit and her in-court testimony.

The case was initially tried in the Regional Trial Court (RTC) of Misamis Oriental, Branch 42, where ZZZ was convicted on both charges in a Joint Decision dated April 16, 2020.
The Court of Appeals (CA) affirmed the RTC’s decision in its Decision dated March 29, 2022.
Post-conviction, ZZZ filed an appeal arguing that the prosecution did not prove his guilt beyond reasonable doubt, particularly targeting the credibility of AAA’s testimony.

Whether the Court of Appeals correctly affirmed the RTC’s ruling finding ZZZ guilty of Qualified Rape under Article 266-A, paragraph 1(a) of the RPC and Child Abuse under Section 5(b), Article III of RA 7610.
Whether the discrepancies pointed out by the defense between AAA’s affidavit and her courtroom testimony are sufficient to undermine her credibility and, by extension, the prosecution’s case.
Whether the evidence on record, including AAA’s corroborative medical and testimonial evidence, establishes ZZZ’s guilt beyond reasonable doubt.