Case Summary (G.R. No. 263227)
Key Dates
• March 7, 2015 – First rape of AAA
• March 9, 2015 – Second rape of AAA
• March 13, 2015 – Rape of BBB
• March 16, 2015 – Victims’ medical examination and formal reporting
• July 23, 2015 – Filing of three Informations for rape
• August 25, 2020 – RTC consolidated judgment convicting XXX
• February 23, 2022 – Court of Appeals decision affirming RTC
• August 2, 2023 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution
• Revised Penal Code, Articles 266-A and 266-B as amended by Republic Act No. 8353 (Qualified Rape/Incestuous Rape)
• Republic Act No. 7610 and RA No. 9262; Rule on Violence Against Women and Their Children (victim anonymity and child protection)
Procedural History
• RTC (Criminal Case Nos. 3068-3070-2015) found XXX guilty beyond reasonable doubt of three counts of incestuous rape and imposed reclusion perpetua without parole plus P100,000 civil indemnity, moral and exemplary damages per count.
• CA in CA-G.R. CR-HC No. 02676-MIN denied XXX’s appeal on February 23, 2022, upholding the credibility of minor victims’ testimonies despite minor inconsistencies.
• XXX elevated the case to the Supreme Court, reiterating challenges to the victims’ credibility and alleged improbability of their reactions.
Facts
• AAA testified to two separate incidents of rape by her father on March 7 and March 9, 2015, occurring inside the family home while siblings slept or were sent out. She described threats of death, forced removal of clothing, and penile penetration.
• BBB testified to a third incident on March 13, 2015, in which XXX, wearing only underwear, ordered her to lie down, forcibly undressed her and attempted penile penetration, causing hymenal laceration and bleeding.
• CCC received AAA’s disclosure on March 14, referred the matter to the Barangay and MSWDO, which led to CCC’s confrontation with BBB and joint medical examination.
• Dr. Pimentel’s March 16, 2015 certificates recorded two hymenal lacerations on AAA and one on BBB.
Issue
Whether the prosecution proved beyond reasonable doubt that XXX committed three counts of incestuous rape under Articles 266-A and 266-B of the Revised Penal Code as amended.
Court’s Analysis
• Elements of Qualified Rape (incestuous rape): (1) sexual congress by force or intimidation; (2) victim is under 18; (3) offender is parent of victim. All elements were established by consistent victim testimonies and medical findings.
• Minor inconsistencies in victims’ recollections are expected given their age and traumatic circumstances; such discrepancies do not impair credibility.
• Medical evidence corroborated the victims’ accounts.
• Defense arguments regarding victims’ supposed “abnormal” reactions (silence, failure to call out or flee) were rejected based on jurisprudence acknowledging the dyn
Case Syllabus (G.R. No. 263227)
Procedural History
- On July 23, 2015, three separate Informations were filed in the RTC, charging XXX, the biological father of the complainants, with three counts of rape (Criminal Case Nos. 3068-2015, 3069-2015, 3070-2015).
- XXX pleaded not guilty at arraignment and the case proceeded through pre-trial and trial on the merits.
- The RTC, in an August 25, 2020 Consolidated Judgment, found XXX guilty beyond reasonable doubt of incestuous rape under Article 266-B of the Revised Penal Code, as amended by RA 8353, and sentenced him to reclusion perpetua without parole for each count, with civil, moral, and exemplary damages fixed at ₱100,000 each.
- On February 23, 2022, the Court of Appeals affirmed the RTC’s conviction and sentence in CA-G.R. CR-HC No. 02676-MIN.
- XXX appealed to the Supreme Court, raising the same credibility and factual consistency arguments rejected by both lower tribunals.
Facts
- Victims AAA and BBB are minor daughters of XXX (14 years old at the time of the first two incidents; 11 years old at the time of the third).
- First incident (March 7, 2015): At around 10:00 p.m., inside the family home, XXX entered the room where AAA and her siblings were sleeping, threatened to kill her if she resisted, lay beside her, removed her clothing, and inserted his penis into her vagina from behind.
- Second incident (March 9, 2015): At around 7:00 a.m., after sending the other siblings to bathe, XXX summoned AAA indoors, undressed her against her protests, ordered her to bend over, and again inserted his penis into her vagina from behind.
- Third incident (March 13, 2015): Inside the house while other family members were away, XXX, wearing only underwear, ordered BBB to lie down, positioned himself atop her, removed her garments, inserted his penis into her vagina (causing pain and bleeding), and threatened to kill the family if she reported the assault.
- Disclosure: On March 16, 2015, older sister CCC, after a Barangay-assisted meeting and MSWDO referral, learned of AAA’s report and then BBB’s confirmation.
- Medical exams by Dr. Florilyn Pimentel on March 16, 2015, revealed two hymenal lacerations on AAA and one on BBB.
Prosecution’s Evidence
- Testimony of AAA: ages 14 at offense, 16 at trial; detailed narrative of two rapes with threats, confirmed insertion of penis into vagina.
- Testimony of B