G.R. No. 257134 - XXX57134 vs. People

Crim. Case No. 15-0425 for Acts of Lasciviousness under Article 336 of the Revised Penal Code (RPC), in relation to Section 5 (b) of Republic Act No. 7610 (RA 7610).
Crim. Case No. 15-0427 for Rape under Article 266-A of the RPC, as amended by RA 8353, in relation to Section 5 (b) of RA 7610.

Both charges involved victim AAA257134, a minor and the petitioner's nephew by adoption.

In Crim. Case No. 15-0425, petitioner allegedly committed acts of lasciviousness against the 6-year-old victim by making him hold his penis and perform masturbation, without the victim's consent.
In Crim. Case No. 15-0427, on June 14, 2014, petitioner allegedly forcibly inserted his penis into the anal orifice of the then 9-year-old victim, constituting rape.

The victim testified to repeated molestation by petitioner, approximately 200 times starting from when he was six years old.
The victim described specific incidents, including one on his seventh birthday, and the June 14, 2014 incident involving anal penetration and attempted oral penetration.
The victim revealed he was afraid to report due to fear and suffered physical symptoms such as sores and pain.
The victim’s mother reported the abuse following disclosure and filed complaints.
A medico-legal examination was conducted but showed no abrasion or laceration.

Petitioner's mother and the victim’s nannies testified that petitioner rarely visited and was never alone with the victim.
They alleged the victim had a tendency to lie and that such acts would have been witnessed if true.
Petitioner denied the allegations and claimed alibi and questioned inconsistencies in the victim’s testimony.
Petitioner also emphasized the negative medico-legal report.

Found petitioner guilty beyond reasonable doubt of acts of lasciviousness and rape.
Sentenced petitioner to imprisonment with detailed penalties per crime.
Ordered payment of civil, moral, and exemplary damages with interest.

Reclassified crime in Crim. Case No. 15-0425 as Child Abuse with adjusted penalties and damages.
Classified Crim. Case No. 15-0427 as Qualified Rape through Sexual Assault with adjusted penalties and damages.

Emphasized the credibility of the child-victim, acknowledging minor inconsistencies as expected and as indicators of truthfulness.

Whether the Court of Appeals erred in affirming the RTC's finding of guilt against petitioner for Acts of Lasciviousness and Rape/Sexual Assault.
Whether the allegations against petitioner were sufficiently proven beyond reasonable doubt.
The proper classification and nomenclature of the crimes committed given the victim's age and relationship to petitioner.
Whether the absence of physical injuries in the medico-legal report negates the commission of sexual abuse.