G.R. No. 263553 - People vs. XXX63553, accused-appellant

The accused-appellant (XXX263553) was charged with five counts of incestuous rape under Article 266-A(1)(a) of the Revised Penal Code, as amended by Republic Act No. 8353.
The victim, AAA263553, is the accused-appellant’s 14-year-old granddaughter at the time of the offenses, occurring from January to May 2015.
The five separate criminal cases correspond to incidents alleged to have taken place in January, February, March, April, and May 2015.

The accused, using threats and intimidation, allegedly had carnal knowledge of AAA263553 on five occasions, against her will.
The offenses are described as willful, unlawful, and felonious acts of sexual penetration through force or intimidation.

AAA263553 testified to being sexually abused by the accused since before she turned 10, with escalating abuse culminating in rape at age 13 and continuing until May 2015. She described threats and physical violence used to silence her.
BBB263553, AAA263553’s younger brother, testified that he witnessed one incident of the accused forcibly having sexual relations with his sister and overheard threats made to keep silent.
Elmer V. Sandag (catechist teacher) corroborated hearing the victim’s disclosure and facilitating reporting to authorities.
Dr. Eleanor Diapana identified medical findings consistent with sexual abuse in the medico-legal examination of AAA263553.

DDD263553, accused’s daughter and victim’s aunt, testified that on May 17, 2015, she was with the accused and did not observe any suspicious behavior with AAA263553.
The accused denied all allegations, presented an alibi for the dates in question, and denied any ill will or motive to fabricate charges.

The Regional Trial Court found the accused guilty of all five counts of incestuous rape, giving greater weight to the prosecution’s testimonies and medical evidence over the accused’s alibi and denial.
The accused was sentenced to reclusion perpetua without possibility of parole, and ordered to pay civil indemnity, moral, and exemplary damages for each count.

The accused appealed, arguing the inconsistencies and delays in reporting, lack of fresh physical evidence, and failure of prosecution to prove relationship and qualifying circumstances beyond doubt.
The People countered that the victim’s minority and relationship to accused were established, as well as carnal knowledge through threats or intimidation.
The Court of Appeals affirmed the RTC ruling, finding the prosecution’s evidence credible and convincing, and the accused’s denial weak.

Whether or not the accused-appellant is guilty beyond reasonable doubt of five counts of qualified rape under Article 266-A(1)(a) in relation to Article 266-B(1) of the Revised Penal Code, as amended.

Whether the prosecution sufficiently established the elements of rape, including especially:

Whether the accused-appellant’s denial and alibi raised reasonable doubt warranting acquittal.