Title
Supreme Court
People vs. XXX accused-appellant
Case
G.R. No. 263227
Decision Date
Aug 2, 2023
Accused-appellant convicted of three counts of Qualified Statutory Rape against his minor daughters; affirmed by Supreme Court with reclusion perpetua and damages.

Case Digest (G.R. No. 263227)
Expanded Legal Reasoning Model

Facts:

  • Background
    • On July 23, 2015, three separate Informations were filed charging accused-appellant XXX with incestuous rape under Article 266-B of the Revised Penal Code, as amended by RA 8353.
    • Criminal Case Nos.:
      • No. 3068-2015 – rape of AAA on March 7, 2015 (victim aged 14).
      • No. 3069-2015 – rape of AAA on March 9, 2015 (victim aged 14).
      • No. 3070-2015 – rape of BBB on March 13, 2015 (victim aged 11).
  • Trial Proceedings
    • Prosecution Version
      • AAA testified to two rape incidents by her father on March 7 and 9, 2015; BBB testified to a rape by her father on March 13, 2015.
      • Dr. Pimentel’s medical examination on March 16, 2015, revealed hymenal lacerations (two on AAA; one on BBB).
    • Defense Version
      • XXX denied all allegations, claimed animosity with sister CCC as motive, and asserted he was absent looking for money when charges arose.
      • He alleged AAA and BBB bore resentment for prior discipline and that CCC instigated the complaints.
  • Lower Court Decisions
    • Regional Trial Court (Aug. 25, 2020) – Found XXX guilty beyond reasonable doubt of three counts of incestuous rape; imposed reclusion perpetua without parole for each count plus civil, moral, and exemplary damages of ₱100,000 each.
    • Court of Appeals (Feb. 23, 2022) – Affirmed the RTC decision, ruling minor inconsistencies in the child-victims’ testimonies did not undermine their credibility.

Issues:

  • Whether the prosecution proved accused-appellant XXX’s guilt beyond reasonable doubt for three counts of incestuous rape.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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