Case Summary (G.R. No. 265272)
Charges and Conviction
ZZZ faced charges for Qualified Rape under Article 266-A, paragraph 1(a) of the Revised Penal Code (RPC) and Child Abuse under Section 5(b), Article III of Republic Act No. 7610 (RA 7610). The Regional Trial Court (RTC) of Misamis Oriental convicted ZZZ on April 16, 2020, following a trial where both AAA's testimony and corroborating evidence were presented. The Court of Appeals (CA) affirmed this conviction on March 29, 2022.
Testimony of the Victim
AAA testified that on November 28, 2016, ZZZ entered her room, removed her pants and underwear, and assaulted her. She described feeling terrified and noted that ZZZ threatened her with violence if she reported the incident. On December 12, 2016, a similar event occurred, where ZZZ again assaulted her and threatened her life and the safety of her siblings. This testimony indicated a pattern of abuse and intimidation.
Defense and Denial
ZZZ denied the allegations, claiming he was sleeping in the same room as multiple family members at the time of the incidents. He asserted that nothing unusual happened and characterized AAA as an obedient child without motive to fabricate such claims.
RTC and CA Findings
The RTC found sufficient evidence to convict ZZZ of both charges, citing AAA's credible and consistent testimony, corroborating medical findings, and the testimony of her sister BBB, who noted improper behavior by ZZZ. The CA upheld these findings, indicating the credibility of AAA's testimony was key to establishing ZZZ's guilt beyond a reasonable doubt.
Legal Assessment
The Court ruled that the elements of Qualified Rape were established—ZZZ had sexual intercourse with AAA, who was under eighteen and related to him. Moreover, the intimidation exerted by ZZZ fulfilled the requirements of rape under the law, particularly in cases of familial abuse where moral ascendancy is present.
Conclusion of Legal Proceedings
The Court affirmed ZZZ's conviction for Qualified Rape an
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Background Information
- ZZZ was charged with Qualified Rape under Article 266-A, paragraph 1(a) of the Revised Penal Code (RPC) and violation of Section 5(b), Article III of Republic Act No. 7610 (RA 7610).
- The charges were filed in the Regional Trial Court of Misamis Oriental, Branch 42.
- The RTC convicted ZZZ for both offenses in a Joint Decision dated April 16, 2020, which was later affirmed by the Court of Appeals (CA) in a Decision dated March 29, 2022.
- ZZZ filed a Notice of Appeal on April 28, 2022, which was granted by the CA.
The Facts
Version of the Prosecution
- The victim, AAA, is the biological daughter of ZZZ and YYY, with whom ZZZ has six children.
- AAA was 14 years old at the time of the incidents.
- On November 28, 2016, ZZZ entered AAA's room while she was napping, removed her pants and underwear, fondled her, and raped her, threatening her to remain silent.
- On December 12, 2016, ZZZ again entered AAA's room, fondled and raped her, while threatening her life and that of her siblings.
- AAA's younger sister, BBB, testified that ZZZ began sleeping with AAA after their mother started working elsewhere.
- AAA eventually disclosed the abuse to her mother, leading to the police report.
- Medical examinations revealed lacerated wounds consistent with sexual abuse.
Version of the Defense
- ZZZ denied the charges, claiming he was with other family members during the alleged incidents.
- He asserted that nothing unusual