Case Summary (G.R. No. 270317)
Applicable Law
The applicable legal framework for this case includes provisions from the Revised Penal Code of the Philippines, specifically Articles 336 for acts of lasciviousness and 266-A pertaining to rape. Additional context is provided by Republic Act No. 7610, also known as the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act.
Summary of Facts
On March 10, 2015, two initial Informations were filed against XXX270317 for acts of lasciviousness and rape through sexual assault, specifically targeting his daughters AAA270317, 10 years old, and BBB270317, 8 years old. The allegations detail grievous acts, including sexual penetration and the employment of various means such as force and intimidation over a period ranging from 2013 to 2015.
Judicial Proceedings
After pleading not guilty during the arraignment, the accused was subjected to a joint trial for the combined criminal cases. The prosecution presented testimonies from both daughters, who provided consistent and compelling accounts of the sexual abuse, framing them as credible witnesses. The defense primarily relied on alibi and denial, asserting that the allegations stem from familial conflict and financial grievances.
The RTC’s Decision
On October 1, 2019, the RTC found XXX270317 guilty beyond reasonable doubt on all counts. The court characterized the testimonies of the victims as credible and determined that all elements of the alleged crimes were sufficiently proven. The court imposed various penalties including imprisonment and monetary damages to the victims due to their suffering.
Court of Appeals’ Reaction
The CA, in its September 27, 2022 decision, upheld the RTC's rulings on guilt while modifying the penalties associated with the crimes. It affirmed the conviction for acts of lasciviousness and several counts of rape, accentuating that the prosecution had established the presence of all required elements beyond reasonable doubt.
Legal Principles Involved
The case underscores crucial legal principles in the prosecution of sexual offenses, particularly regarding the credibility of child witnesses, the standards of proof requirement in sexual assault cases, and the implications of familial relationships in the commission of these crimes. The Court reiterated that medical evidence while helpful, is not strictly necessary for
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Facts of the Case
- On March 10, 2015, two informations were filed against accused-appellant XXX270317, charging him with acts of lasciviousness and rape by sexual assault involving his minor daughters, AAA270317 (10 years old) and BBB270317 (8 years old).
- Additional six informations were filed on June 15, 2015, charging him with five counts of rape through sexual assault and statutory rape concerning incidents occurring between 2013 and 2015.
- Accused pleaded not guilty to all charges.
- Joint trial conducted with testimonies from victims AAA270317 and BBB270317, and teacher CCC270317.
- Accused testified denying all charges, claiming alibi and denying ever being alone with his daughters.
Nature and Details of the Crimes Charged
- Acts of lasciviousness under Article 336 of the Revised Penal Code, in relation to Section 5(b) of Republic Act No. 7610.
- Six counts of rape by sexual assault under Article 266-A(2) of the Revised Penal Code, in relation to Section 5(b) of Republic Act No. 7610.
- Statutory rape under Article 266-A(1)(d) of the Revised Penal Code.
- The acts involved sexual touching, digital penetration, and penile penetration, including anal rape of minor victims.
Testimonies and Evidence
- AAA270317 detailed multiple instances of lascivious acts and rape involving touching of breasts and vagina and penile penetration, starting from 2013.
- BBB270317 recounted multiple instances of penile anal penetration between 2014 and 2015.
- Teacher CCC270317 heard AAA270317’s disclosure and reported to authorities.
- Defense witnessed accused’s claims of working multiple jobs and having no opportunity to commit crimes.
- Prosecution’s evidence included victim testimonies and affidavits; medical certificates and medico-legal examiner testimonies were not presented.
Findings of the Regional Trial Court (RTC)
- RTC found accused guilty beyond reasonable doubt of all charges.
- Credited the testimonies of victim witnesses as credible, clear, positive, and convincing.
- Denied the defense claims of denial and alibi for lack of evidence.
- Imposed penalties and ordered indemnification to victims.
Appeal and Court of Appeals (CA) Decision
- Accused-appellant appealed, questioning credibility of victims and lack of medical evidence.
- CA upheld RTC ruling with modifications, including changes to penalties and civil liabilities.
- CA found accused guilty as charged, but convicted him of qualified statutory rape instead of simple rape.
Issues for Supreme Court Resolution
- Whether accused-appellant is gui