G.R. No. 211026 - People vs. Suedad

Case Summary (G.R. No. 211026)

Charges and Statutory Basis

Appellant was charged in four informations (Criminal Cases Nos. 115–118) with qualified rape in violation of Article 266-A, paragraph 1, in relation to Article 266-B of the Revised Penal Code, and Republic Act No. 7610 (special protection of children).
The informations allege carnal knowledge of AAA, an eleven‑year‑old child, on specified dates in October and November 2008 and March 2009. Under Article 266‑A(1), sexual congress with a woman under twelve years of age constitutes rape regardless of force or consent; Article 266‑B prescribes reclusion perpetua for such rape, with statutory attendant circumstances (e.g., offender is a parent) potentially elevating penalty severity.

Factual Allegations

AAA alleged multiple incidents of sexual intercourse with her father beginning on 20 October 2008 and continuing on dates including the last week of October 2008, 26 November 2008 (during the paternal grandmother’s wake), and 20 March 2009.
AAA described the acts as repeated and detailed; she reported the abuse to her grandmother on 15 April 2009 and a complaint was filed on 21 April 2009.
Background context: AAA’s mother worked overseas when AAA was under two years old, leaving AAA largely in the care of appellant.

Evidence Presented by the Prosecution

Witnesses: AAA (victim), BBB (mother), CCC (maternal grandmother), DDD (maternal aunt), and Dr. Raul Manansala (Municipal Health Officer).
Medico‑legal report by Dr. Manansala: documented partial healed lacerations of the hymen at 9 o’clock and 3 o’clock, and that the hymenal orifice admitted one finger with ease; findings consistent with repeated sexual contact and laceration depending on hymenal thickness. Dr. Manansala explained that a thick hymen may not lacerate on first intercourse, and frequent sexual contact may produce lacerations.
Stipulation at pre‑trial: AAA’s birthdate and that appellant is her biological father.

Defense Position and Evidence

Appellant admitted to being physically intimate with AAA at times but denied the rape charges as legally constituted.
He alleged ill motives behind the complaint: that AAA had written a sensual letter to a boyfriend and threatened disclosure; and that CCC intended to file charges to take AAA away from him, citing longstanding quarrels.
Defense witnesses included a nephew and a niece offered to support appellant’s denial for specific dates.

Trial Court Findings and Sentence

The Regional Trial Court (Branch 19, Isulan) credited AAA’s testimony and the medico‑legal evidence, finding appellant guilty beyond reasonable doubt of three counts of qualified rape (Criminal Cases Nos. 115, 117, 118) and acquitted him in one count (Criminal Case No. 116) where evidence was found insufficient.
Sentence imposed by the RTC: reclusion perpetua for each conviction; indemnity P50,000 and moral damages P30,000 for each count.

Court of Appeals Decision

The Court of Appeals affirmed the RTC with modification: it found appellant guilty of qualified rape, sentenced him to reclusion perpetua without eligibility for parole for each count, and increased the awards to P75,000 civil indemnity, P75,000 moral damages, and P30,000 exemplary damages per count, with statutory interest of 6% per annum from finality.

Supreme Court’s Review: Facts, Credibility and Legal Standards

The Supreme Court reviewed the case on appeal. It reiterated controlling principles: (a) sexual congress with a girl under twelve is always rape under Article 266‑A(1) and consent is immaterial; (b) the complainant’s testimony is central and can alone sustain conviction if credible, natural, consistent and in consonance with human experience; and (c) trial courts’ credibility determinations merit great respect absent clear error, given their opportunity to observe witnesses.
The Court affirmed the trial courts’ assessment that AAA’s testimony was clear, spontaneous, categorical and consistent. It gave significant weight to the victim’s testimony as a child and noted that youth often carries an aura of truthfulness.
Medical findings corroborated the victim’s account: healed hymenal lacerations support a conclusion of forcible defloration or repeated sexual intercourse, strengthening the testimonial evidence.
The Court addressed common defense tactics: delay in reporting was explained by fear arising from threats and moral ascendancy; alleged ill motives among family members were insufficient to displace affirmative and categorical declarations of rape by the child; and the contention that an event could not have occurred during a wake because many people were present was rejected as unrealistic given that sexual offenders may commit abuse notwithstanding surrounding persons.

Legal Effect of Republic Act No. 9346 and Penalty

The Court noted Republic Act No. 9346 (abolishing the death penalty for certain crimes) made the death penalty inapplicable; hence reclusion perpetua was the appropriate punishment for the qualified rape convictions despite attendant circumstances.

Supreme Court Holding and Modification of Damages

The Supreme Court affirmed appellant’s conviction for three counts of qualified rape. It modified prior monetary awards by increasing damages for each count to: P100,000 civil indemnity, P100,000 moral damages, and P100,000 e

Case Syllabus (G.R. No. 211026)

Title, Docket and Panel

Case title as styled in the source: PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RENATO B. SUEDAD, ACCUSED-APPELLANT.
Supreme Court docket reference: G.R. No. 211026; Decision date: June 08, 2016.
Case originated from the Regional Trial Court (RTC) of Isulan, Sultan Kudarat, Branch 19, in Criminal Case Nos. 115, 116, 117 and 118.
Court of Appeals case: CA-G.R. CR.-H.C. No. 00955-MIN; Court of Appeals decision dated 6 September 2013.
Supreme Court panel: Associate Justice Perez penned the decision; concurrence noted by Velasco, Jr. (Chairperson), Reyes, and Perlas-Bernabe, JJ.; Peralta, J. on official leave. Additional member per raffle: noted.

Parties and Identities Protected

Plaintiff-Appellee: People of the Philippines.
Accused-Appellant: Renato B. Suedad (also referred to as Renato Bolivar Suedad).
Rape victim’s real name withheld pursuant to People v. Cabalquinto; victim is referred to as AAA.
Victim’s mother is referred to as BBB; maternal grandmother as CCC; maternal aunt as DDD.
The decision reaffirms that the real name and identity of the rape victim and members of her immediate family are not disclosed.

Criminal Informations and Charges

Four separate Informations charging qualified rape under Article 266-A, paragraph 1 in relation to Article 266-B of the Revised Penal Code and Republic Act 7610.
Criminal Case No. 115: Alleged date and time — October 20, 2008, about 5:00 PM, in the victim’s house in Purok [xxx], Barangay [xxx], Municipality of Isulan, Sultan Kudarat; accused alleged to have had carnal knowledge of his daughter, AAA, then eleven (11) years old, against her will and consent.
Criminal Case No. 116: Alleged date — during the night during the last week of October 2008, at their house in Purok [xxx], Barangay [xxx], Municipality of Bagumbayan, Sultan Kudarat; accused alleged to have had carnal knowledge of AAA, then eleven (11) years old, against her will and consent.
Criminal Case No. 117: Alleged date and time — November 26, 2008, about 11:00 PM, at the house of her grandmother (paternal), Purok [xxx], Barangay [xxx], Municipality of Bagumbayan, Sultan Kudarat; accused alleged to have had carnal knowledge of AAA, then eleven (11) years old, against her will and consent.
Criminal Case No. 118: Alleged date and time — March 20, 2009, about 9:00 AM, in their house in Purok [xxx], Barangay [xxx], Municipality of Bagumbayan, Sultan Kudarat; accused alleged to have had carnal knowledge of AAA, then eleven (11) years old, against her will and consent.
All Informations characterize the acts as demeaning, degrading and debasing the intrinsic worth of the child as a human being.

Plea, Pre-trial Stipulations and Trial Commencement

Appellant pleaded not guilty to all charges.
At pre-trial, parties stipulated that AAA was born on 5 July 1997 and that appellant is her natural/biological father.
Trial on the merits ensued following the pre-trial proceedings.

Prosecution Witnesses and Core Prosecution Evidence

Prosecution presented the following witnesses: AAA (victim), BBB (mother), CCC (maternal grandmother), DDD (maternal aunt), and Dr. Raul Manansala (Municipal Health Officer of Bagumbayan).
Prosecution established: AAA is the only child of BBB and appellant; AAA was born on 5 July 1997.
Historical family circumstance presented: When AAA was less than two years old, BBB worked overseas and AAA was left in the care of her father; BBB only returned home occasionally.

Victim’s Testimony and Factual Narrative as Elicited

AAA’s account:
- First incident: October 20, 2008, at about 5:00 PM in their home — appellant’s initial affectionate gestures led to sexual intimacy she associated only with husband and wife.
- Subsequent incident: during the last week of October 2008 — appellant repeated the acts; AAA vaguely remembered particulars.
- November 26, 2008: During her paternal grandmother’s wake at the grandmother’s house, while AAA was sleeping in one of the rooms, appellant woke her, choked her, and succeeded in having sexual congress with her.
- March 13 (noted in one part of the record) and March 20, 2009: Within their house, appellant once more had carnal knowledge of AAA; the operative Information alleges March 20, 2009.
- AAA reported that appellant treated her as his wife and indicated these incidents may represent only a portion of repeated abuses.
AAA disclosed the abuse to her grandmother CCC on 15 April 2009 despite death threats; complaint filed before the prosecutor’s office on 21 April 2009.
AAA accompanied by her aunt underwent physical (medico-legal) examination on 16 April 2009 by Dr. Manansala.

Medico-Legal Examination and Findings

Dr. Raul Manansala’s medico-legal report findings (as recorded in the source):
- “PARTIAL HEALED LACERATION 9 o'clock, 3 o'clock, HYMEN ADMIT (SIC) 1 FINGER WITH EASE.”
Dr. Manansala’s testimony explained:
- An eleven (11) year old girl who has had frequent sexual contact may suffer full or partial lacerations depending on the thickness of the hymen.
- A thick and elastic hymen may accommodate the male anatomy without lacerations.
- AAA was found to have a thick hymen.
The court’s articulation: hymenal lacerations, whether healed or fresh, are regarded as the best evidence of forcible defloration; when the victim’s straightforward testimony aligns with medical findings, the essential requisites of carnal knowledge can be established.

Defense Case, Admissions and Contentions

Appellant admitted to being physically intimate with AAA during the days alleged but denied that such acts constituted rape.
Defense contentions and asserted motives:
- Alleged ill motive on part of AAA: AAA allegedly held a grudge against appellant after he discovered a sensual letter AAA wrote to one Marvin, purported boyfriend; AAA allegedly threatened to reveal this to BBB.
- Alleged conspiracy or plan by CCC to file criminal cases to remove AAA from appellant’s custody.
- History of quarrels between CCC and appellant over several issues.
Defense witnesses included a nephew and a niece who were presented to support appellant’s denial of the rape charges for specific dates (26 Novem