Case Summary (G.R. No. 255491)
Charges and Proceedings
Accused-appellant XXX was charged on three separate occasions with Qualified Statutory Rape under Article 266-A and Article 266-B of the Revised Penal Code (RPC). The allegations were based on incidents occurring between 2004 and 2007. During these incidents, the accused is alleged to have used force and intimidation against his minor daughter, AAA, who was between 9 and 11 years old at the time.
Trial and Evidence Presented
During the trial, the prosecution presented multiple witnesses including AAA, her mother BBB, her brother CCC, and a medico-legal officer, Marianne S. Ebdane. The testimony of AAA was pivotal as she recounted being sexually abused by her father. Although no physical injuries were found during a medical examination, Officer Ebdane confirmed that it is not unusual for evidence of assault to be absent in cases involving minors. The defense primarily relied on the testimony of accused-appellant, who denied the allegations and attributed potential motives to BBB.
Ruling of the Regional Trial Court
In an Omnibus Judgment on August 9, 2017, the Regional Trial Court convicted XXX of Qualified Statutory Rape. The court emphasized the credibility of AAA’s testimony, deeming her straightforward and sincere. The dimensions of the case centered on the elements required to prove statutory rape, specifically the minority of the victim and the abusive relationship between the accused and AAA. The trial court rejected defenses of denial and alibi, focusing instead on the compelling evidence presented by the prosecution.
Court of Appeals Ruling
The Court of Appeals, on September 27, 2019, upheld the conviction but increased the monetary damages awarded to AAA. It affirmed that the prosecution had clearly demonstrated that carnal knowledge occurred without AAA’s consent and reiterated that even in the absence of physical evidence, credible testimony alone could lead to a conviction for such a serious crime.
Supreme Court Ruling
Upon further appeal by the accused, the Supreme Court dismissed the appeal, stating that the trial court’s findings on credibility must be respected. The Court noted that inconsistencies in a victim's testimony do not inherently undermine its overall credibility, especially in light of minor discrepancies. The Supreme Court reiterated the
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Case Information
- Court: Supreme Court of the Philippines
- Division: Second Division
- G.R. No.: 255491
- Decision Date: April 18, 2022
- Nature of Case: Appeal regarding conviction for Qualified Statutory Rape
Overview of the Case
- This appeal contests the September 27, 2019 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 09868.
- The CA modified the August 9, 2017 Omnibus Judgment of the Regional Trial Court, finding accused-appellant XXX guilty of Qualified Statutory Rape under Article 266-A, paragraph 1(d), in relation to Article 266-B of the Revised Penal Code (RPC).
Antecedents
- Incident Dates:
- March 13, 2007 (Criminal Case No. 33-09)
- Year 2004 (Criminal Case No. 34-09)
- Year 2005 (Criminal Case No. 35-09)
- Victim: AAA, daughter of accused-appellant, born on May 14, 1995.
- Charges: Accused-appellant charged with having carnal knowledge of AAA against her will on three separate occasions.
Criminal Informations
Criminal Case No. 33-09:
- Date: March 13, 2007
- Description: Accused-appellant used force and intimidation to have carnal knowledge of his 11-year-old daughter.
Criminal Case No. 34-09:
- Date: Year 2004
- Description: Similar charges for the act committed against his 9-year-old daughter.
Criminal Case No. 35-09:
- Date: Year 2005
- Description: Similar charges for the act committed against his 10-year-old daughter.
Proceedings
- Accused-appellant pleaded not guilty.
- Joint trial ensued, with the prosecution presenting AAA, her mother BBB, brother CCC, and a medico-legal officer.
- The defense presented accused-appellant as its sole witness.
Prosecution's Version
- On March 13, 2007, while AAA was washing dishes, accused-appellant isolated her by sending other siblings out.
- Accused-appellant ordered AAA to change into a skirt and subsequently committed the act of rape.
- Subseque