Case Summary (G.R. No. 268654)
Summary of Facts
XXX was charged with three counts of qualified rape against his daughter, AAA. The specifics of the charges outlined incidents that occurred in October and December 2013, and November 2014, during which it was alleged that he committed acts of sexual violence against her, taking advantage of his parental authority. Upon arraignment, XXX pleaded not guilty, and the case proceeded to trial.
Prosecution’s Evidence
The prosecution's case relied heavily on the testimony of AAA, who recounted the traumatic experiences of her father's sexual assaults. AAA's accounts indicated that the rapes occurred on three distinct occasions—October 2013, December 2013, and November 2014. She described in detail how XXX overpowered her, and medical evidence from Dr. Borja indicated injuries consistent with sexual assault.
Defense's Claims
XXX maintained his innocence, suggesting that he was not present during the alleged incidents, claiming that AAA was with their grandfather and siblings on those occasions. He attempted to challenge the accusations based on a claim of alibi.
Trial Court's Decision
The Regional Trial Court (RTC) found AAA's testimony credible, declaring the accused guilty of three counts of qualified rape. The RTC sentenced XXX to reclusion perpetua and imposed civil and moral damages to be paid to AAA.
Appeal to the Court of Appeals (CA)
Following the RTC's ruling, XXX appealed to the Court of Appeals, which upheld the conviction while modifying the designation to "qualified statutory rape." The CA emphasized that AAA was below 12 years old when the crimes were committed, thereby fulfilling the legal criteria for this charge.
Issue Presented for Review
The primary issue presented was whether the Court of Appeals erred in convicting XXX of three counts of qualified statutory rape.
Supreme Court's Rulings
The Supreme Court found no merit in the appeal, confirming the findings of the lower courts. The Court underscored the necessity of protecting minor victims from sexual offenses and highlighted the significant evidential value of the victim's testimony and corroborating medical evidence.
Designation of Crime
The Court clarified the distinction between qualified rape and qualified statutory rape, affirming that due to the relationship between the offender and the victim, the crime is rightly characterized as qualified rape rather than merely statutory rape.
Penalties and Damages
The Supreme Court reaffirmed the penalties imposed by the lowe
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Facts of the Case
- Accused-appellant XXX was charged with three counts of qualified rape involving his then minor daughter, AAA.
- The incidents occurred separately in October 2013, December 29, 2013, and November 23, 2014.
- The victim was aged 9 to 11 years during the commission of the crimes.
- The accusatory portions allege that XXX, abusing his moral ascendancy as AAA's father, used force, intimidation, and his position to commit the acts against her will.
- At arraignment, XXX pleaded not guilty to all charges.
- Trial was conducted with the victim as the lone prosecution witness.
- AAA detailed the three separate occasions where she was raped by the accused, describing acts of force despite her resistance.
- The victim’s mother, BBB, upon learning of the abuse, helped file a criminal complaint.
- Medical examination findings indicated physical evidence of abuse, with a non-intact hymen and healed hymenal laceration.
- The birth certificate established the victim’s age and filial relationship to XXX.
- The accused denied the charges and presented an alibi defense.
Trial Court Decision (RTC)
- The RTC gave credence to the victim’s straightforward and spontaneous testimony.
- The court found XXX guilty beyond reasonable doubt of three counts of qualified rape.
- Each count was sentenced to reclusion perpetua.
- The court awarded PHP 100,000.00 each for civil indemnity, moral damages, and exemplary damages, with 6% interest until fully paid.
Court of Appeals (CA) Decision
- The CA affirmed the conviction but modified the qualification of the crime to qualified statutory rape based on the victim’s age and relationship with the offender.
- Sentences of reclusion perpetua were affirmed without eligibility for parole.
- Monetary awards remained the same as RTC but with the same 6% interest.
Issue Presented on Appeal
- Whether the CA erred in convicting the accused of three counts of qualified statutory rape.
Relevant Law and Legal Framework
- Article 266-A, paragraph 1(d) of the Revised Penal Code (RPC), as amended by Republic Act No. 8353, defines statutory rape as carnal knowledge