Case Summary (G.R. No. 36701)
Charges and Subsequent Proceedings
The appellant was indicted for:
- Criminal Case No. 08-0581-2013: Charge of qualified rape involving AAA (15 years old).
- Criminal Case No. 08-0631-2013: Charge of qualified rape involving BBB (14 years old).
- Criminal Case No. 08-0630-2013: Charge of lascivious conduct concerning BBB.
Both rape charges described situations where the appellant allegedly had carnal knowledge of his daughters through force, threat, or intimidation, exploiting their vulnerability as minors. The lascivious conduct charge stemmed from inappropriate touching and actions by the appellant toward BBB.
Trial Court Proceedings
During the trial, AAA recounted her experience in graphic detail, stating that her father forced himself on her on March 14, 2009, while BBB corroborated similar experiences of abuse, indicating a pervasive pattern of sexual violence within the household. The trial court ultimately convicted the appellant based on the credible testimonies of the victims, finding them truthful and consistent despite defense claims of a conspiracy.
Trial Court Ruling
The trial court, in its decision dated June 21, 2016, ruled in favor of the prosecution, sentencing the appellant to reclusion perpetua for the rapes and imposing various monetary penalties as civil indemnity, moral damages, and exemplary damages to both victims.
Proceedings Before the Court of Appeals
On appeal, the appellant challenged the conviction by questioning the credibility of the victims and citing factors such as a lack of physical resistance during the incidents and the delay in reporting the abuse. The Office of the Solicitor General countered that the failure to promptly report was due to the intimidation exerted by the appellant as a parent and the victims' fear of not being believed.
Court of Appeals Ruling
The Court of Appeals upheld the trial court's decision on August 3, 2017, reinforcing the credibility of AAA and BBB. It also increased the amounts awarded for damages to reflect the severity of the offenses and reiterated that the nature of the relationship (parent-child) can inherently create a situation where the victims may not resist out of fear and psychological control.
Issue Presented on Appeal
The primary issue was whether the Court of Appeals erred in affirming the trial court’s decision, particularly concerning the credibility of the victims and the sufficiency of the evidence against the appellant.
Ruling on Appeal
The appeal was dismissed. The Court highlighted that the reactions of AAA and BBB were not atypical for victims of incestuous rape; they did not diminish their credibility. It was also emphasized that the law recognizes moral ascendancy in lieu of physical threats when a close relation, such as a father, is involved.
Final Ruling on Qualified Rape and Lascivious Conduct
Under Articles 266-A and 266-B of the Revised Penal Code, qualified rape was established by
...continue readingCase Syllabus (G.R. No. 36701)
Prefatory
- This appeal challenges the Decision dated August 3, 2017, of the Court of Appeals in CA-G.R. CR-HC No. 08486, which convicted the appellant XXX of two counts of qualified rape and one count of lascivious conduct.
The Proceedings Before the Trial Court
Charges:
- Appellant XXX faced two counts of rape (Criminal Case Nos. 08-0581-2013 and 08-0631-2013) concerning his daughters, AAA (15 years old) and BBB (14 years old), respectively.
- Criminal Case No. 08-0581-2013:
- Incident occurred on March 14, 2009.
- Appellant was charged with raping AAA through force, threat, or intimidation.
- Criminal Case No. 08-0631-2013:
- Similar charges for raping BBB in 2009, using force, threat, and intimidation.
- Criminal Case No. 08-0581-2013:
- In addition to the rape charges, XXX was charged with lascivious conduct against BBB (Criminal Case No. 08-0630-2013) for inappropriate sexual behavior.
- Appellant XXX faced two counts of rape (Criminal Case Nos. 08-0581-2013 and 08-0631-2013) concerning his daughters, AAA (15 years old) and BBB (14 years old), respectively.
Consolidation:
- All three cases were consolidated before the Regional Trial Court, Branch 13, Lipa City.
Appellant's Plea:
- Appellant pleaded not guilty to all charges.
The Prosecution's Evidence
- Testimonies of AAA and BBB:
- Both are daughters of appellant and MMM, the mother.
- AAA testified about being raped multiple times, detailing a specific incident on March 14, 2009.
- BBB described a similar incident where she was sexually assaulted by her father, corroborating the repeated nature of the abuse.
- Both daughters indicated prolonged silence due to disbelief from their mother and fear of their father.
The Defense's Evidence
- Appellant's Claims:
- Appellant denied the charges, claiming he was working during the alleged incidents.
- Cont