G.R. No. 192820, June 4, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RENATO DELA CRUZ, Accused-Appellant.

FACTS

Accused-appellant Renato dela Cruz was charged with two counts of rape against his daughter, AAA. The first Information (Criminal Case No. 3254-M-2004) alleged that in October 1999, in XXX, the accused, by means of force and intimidation, had carnal knowledge of AAA, then 11 years old. The second Information (Criminal Case No. 3253-M-2004) alleged that on September 9, 2003, in XXX, the accused, by means of force and intimidation, had carnal knowledge of AAA, then 15 years old. The accused pleaded not guilty.
The prosecution presented AAA and her elder sister BBB. AAA testified that in October 1999, she was awakened by the accused touching her; he covered her mouth, kissed her, and touched her private parts. On September 9, 2003, the accused woke her, led her to the sala, and inserted his penis into her vagina. BBB testified that she witnessed the accused on top of AAA during the 2003 incident. A medico-legal report confirmed AAA was in a “non-virgin state physically.”
The defense presented only the accused, who denied the allegations. He claimed his daughters filed the case due to anger over his extramarital affair and frequent arguments with BBB.
The Regional Trial Court (RTC) found the accused guilty of acts of lasciviousness for the 1999 incident and rape for the 2003 incident. The Court of Appeals affirmed with modifications to the damages awarded. The accused appealed to the Supreme Court, arguing ill motive of the witnesses and inconsistencies in AAA’s testimony.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crimes charged.

RULING

The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals with modifications.
1. Credibility of Witnesses: The Court found AAA’s testimony credible, straightforward, and consistent. The alleged inconsistencies (e.g., whether the 1999 incident involved rape or acts of lasciviousness) were minor and did not affect her core narrative. The testimony of BBB corroborated AAA’s account. The accused’s claim of ill motive (anger over his extramarital affair) did not undermine the witnesses’ credibility, as motive is not an element of rape.
2. Elements of the Crimes:
– For rape under Article 266-A of the Revised Penal Code, the prosecution proved: (a) carnal knowledge occurred on September 9, 2003, and (b) it was accomplished through force and intimidation. AAA’s age (15) and her relationship to the accused (father) constituted qualifying circumstances.
– For acts of lasciviousness under Article 336, the prosecution proved: (a) the accused kissed and touched AAA’s private parts in October 1999, and (b) AAA was 11 years old at the time.
3. Penalties and Damages:
– For rape (Criminal Case No. 3253-M-2004): The penalty of reclusion perpetua without parole was affirmed. The accused was ordered to pay AAA ₱75,000 as civil indemnity, ₱75,000 as moral damages, and ₱30,000 as exemplary damages, with 6% interest per annum from finality of the decision.
– For acts of lasciviousness (Criminal Case No. 3254-M-2004): The indeterminate penalty of six months of arresto mayor as minimum to six years of prision correccional as maximum was affirmed. The accused was ordered to pay AAA ₱50,000 as civil indemnity, with 6% interest per annum from finality of the decision.
The Court emphasized that the findings of fact by the trial court, affirmed by the Court of Appeals, are entitled to great weight and respect. The accused’s guilt was proven beyond reasonable doubt.