Case Summary (G.R. No. L-29966)
Applicable Law
The relevant laws considered in this case include Article 266-A in relation to Article 266-B of the Revised Penal Code, which governs the definitions and penalties for rape, particularly qualified rape.
Charges and Proceedings
On November 20, 2019, the City Prosecutor initiated charges against XXX270149 for rape, later docketed as Criminal Case No. FC-15-1707. The case was initially dismissed due to a lack of authority by the signing prosecutor, leading to a re-filing on December 12, 2019, as Criminal Case No. FC-19-3112. During the pre-trial, it was stipulated that XXX270149 is the biological father of AAA270149, which formed a critical aspect of the case.
Incident Overview
Testimonies from the victim, AAA270149, and other witnesses detailed a traumatic incident during a visit to a friend’s house. It was described that after AAA270149 called for her father while in the bathroom, XXX270149 assaulted her by inserting his finger and subsequently his penis into her vagina, which was corroborated by the unexpected entry of a witnessing adult, Melody Amboyao, who reported seeing the assault.
Trial and Witness Testimonies
The RTC conducted trial proceedings where the victim's testimony, supported by witness accounts, outlined the events clearly and convincingly. The victim's recounting of the abuse was established with clarity, indicating the physical and emotional pain she suffered, as evidenced by her crying out during the assault.
Verdict of the RTC
The RTC ultimately found XXX270149 guilty of qualified rape under Article 266-A and Article 266-B of the Revised Penal Code. The court imposed the penalty of reclusion perpetua without eligibility for parole, alongside civil indemnity, moral damages, and exemplary damages, each set at PHP 100,000.
Court of Appeals Decision
XXX270149 appealed the decision to the Court of Appeals (CA), challenging the RTC's judgment. However, the CA affirmed the prior ruling, emphasizing that the prosecution had met the burden of proof to establish guilt beyond a reasonable doubt, while dismissing the accused's defenses of denial and alibi as insufficient against the compelling evidence presented.
Supreme Court Ruling
The Supreme Court reviewed the appeal on the basis of whether the accused was guilty beyond a reasonable doubt. The court, maintaining the principle that only questions of law may be raised in such appeals, reaffirmed the factual findings of the lower courts, concluding that the
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Background and Procedural History
- The accused, XXX270149, was charged with violation of Article 266-A in relation to Article 266-B(1) of the Revised Penal Code, as amended, for rape involving his six-year-old daughter, AAA270149.
- Original criminal case was dismissed for lack of authority of the prosecutor; subsequently refiled with proper authority.
- The accused pleaded not guilty; pre-trial and trial on the merits followed.
- Both parties stipulated the accused was the biological father of the minor victim.
Factual Narrative
- AAA270149 lived with the accused, her biological father, after her parents separated.
- On February 16, 2015, the accused and AAA270149 visited a friend's house where the incident occurred.
- Victim testified the accused sexually abused her in the bathroom by first removing her panty and then inserting his finger, followed by his penis into her vagina without consent.
- Victim expressed pain and was visibly upset during the assault.
- A witness, Melody Amboyao, saw the accused inside the bathroom with AAA270149 in a compromising position and noted blood stains on the victim's underwear.
- The accused fled the scene and was later apprehended after a physical confrontation.
- The accused denied the charges and claimed an alibi involving climbing a coconut tree and being assaulted by his friend Joey.
Trial Court Findings and Judgment
- The Regional Trial Court found the accused guilty of qualified rape under Article 266-A paragraph 1(d), qualified by Article 266-B, sentencing him to reclusion perpetua without eligibility for parole.
- The accused was ordered to pay civil indemnity, moral damages, and exemplary damages, including interest.
- The court based its decision on the credible and positive testimony of the victim, corroborated by witnesses, and the stipulation of paternity.
Court of Appeals Decision
- The Court of Appeals affirmed the RTC's judgment, holding that the prosecution proved the accused's guilt beyond reasonable doubt.
- The denial and alibi presented by the accused were deemed insufficient to overcome the strong and credible testimonies against him.
Issues on Appeal
- Whether the accused-appellant XXX270149 is guilty beyond reasonable doubt of qualified rape.