GR 218087; (July, 2021) (Digest)
G.R. No. 218087 , July 06, 2021
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.
FACTS
The accused-appellant, XXX, was charged with two counts of rape against his niece by affinity, AAA, in separate Informations dated June 6, 2001, and August 1, 2003. The first alleged rape occurred during the first week of November 2000, and the second on November 14, 2000, both in Barangay LLL, City of MMM. AAA testified that on both occasions, XXX entered her house surreptitiously at night while she was sleeping, used force, intimidation, and threats, and had carnal knowledge of her against her will. After the incidents, AAA became pregnant, which was later confirmed by a medical examination showing a pregnancy consistent with conception around the dates of the alleged rapes. AAA gave birth to a child fathered by XXX. The defense, however, claimed that AAA and XXX were lovers and that their sexual relations were consensual. XXX admitted to carnal knowledge but asserted it was part of a secret romantic relationship, alleging the charges were instigated by AAA’s mother, BBB, after the pregnancy was discovered. The defense presented witnesses who claimed to have seen AAA and XXX together in intimate circumstances.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s finding that accused-appellant XXX is guilty beyond reasonable doubt of two counts of rape.
RULING
The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The Court held that the prosecution successfully proved all elements of rape through AAA’s credible, categorical, and consistent testimony, which detailed the use of force, intimidation, and threats. The medical finding of pregnancy corroborated her account. The Court rejected XXX’s sweetheart defense as inherently weak and unsupported by credible evidence, noting that such a defense requires clear and convincing proof of a romantic relationship, which was not presented. The Court found AAA’s conduct after the incidents, including her delay in reporting due to threats, to be consistent with that of a rape victim. The awards of damages were sustained, with the imposition of legal interest. Accordingly, XXX was found guilty beyond reasonable doubt of two counts of rape and sentenced to two penalties of reclusion perpetua for each count, with corresponding damages.