G.R. No. 258694 , August 09, 2023
People of the Philippines, Plaintiff-Appellee, vs. YYY258694 and XXX258694, Accused-Appellants.

FACTS

The accused-appellants, YYY258694 and his common-law wife XXX258694 (the older sister of the victim), were charged with sexual abuse under Republic Act No. 7610 . The Information alleged that on August 20, 2016, they conspired to commit sexual abuse against AAA258694, a 15-year-old minor. XXX258694, taking advantage of her moral authority, asked AAA258694 to enter their bedroom, ordered her to lie on the bed, and held her hands while YYY258694 had sexual intercourse with her against her will. XXX258694 watched and used a flashlight to illuminate the act.
The prosecution’s version, as testified by AAA258694, was that around midnight on August 20, 2016, while she was studying, XXX258694 called her into the bedroom. XXX258694, who was heavily pregnant, told AAA258694 to have sex with YYY258694 instead, fearing harm to her unborn child. Despite AAA258694’s refusal, XXX258694 laid her on the bed, held her hands, and YYY258694 proceeded to rape her while covering her mouth. AAA258694 cried and begged for mercy. Afterward, XXX258694 ordered her to wash up. AAA258694 later confided in her sister BBB258694 in June 2017, leading to a medical examination that revealed healed hymenal lacerations consistent with penetrating trauma. An affidavit of desistance was later executed by BBB258694 and AAA258694 in January 2018, which they claimed was done out of pity and due to threats from AAA258694 to run away again.
The defense denied the allegations. XXX258694 claimed she was asleep and that YYY258694 was at work during the alleged incident, asserting that it was actually their brother, CCC258694, who had raped AAA258694 previously. YYY258694 supported this alibi, stating he was working a night shift. They argued the case was fabricated because BBB258694 wanted custody of their child.
The Regional Trial Court found the accused guilty of rape under Article 266-A of the Revised Penal Code, a decision affirmed with modification by the Court of Appeals. The accused appealed to the Supreme Court.

ISSUE

The core issue is whether the guilt of accused-appellants YYY258694 and XXX258694 for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court denied the appeal and affirmed the convictions with modifications. The Court held that all elements of rape under Article 266-A(1) of the Revised Penal Code were proven beyond reasonable doubt. The credible and categorical testimony of AAA258694, which was consistent and detailed, established that YYY258694 had carnal knowledge of her through force and intimidation, and that XXX258694 cooperated in the commission of the crime by using her moral ascendancy to compel AAA258694 and by physically assisting during the act. The medical findings corroborated the victim’s account. The defense of denial and alibi could not prevail over the positive identification and credible testimony of the victim. The affidavit of desistance was properly disregarded as it was executed under pressure and did not equate to a waiver of the crime. The Court modified the awards of damages in accordance with prevailing jurisprudence.