G.R. No. 225339 . July 10, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. XXX, Accused-Appellant.

FACTS

The accused-appellant, the uncle of the private complainant AAA, was charged with rape under Article 266-A of the Revised Penal Code in relation to RA 7610. The prosecution alleged that in the early morning of January 13, 2004, in Camarines Sur, appellant, by means of force and intimidation, had carnal knowledge of his then 16-year-old niece, AAA, while she was sleeping beside her younger brothers. AAA testified that she awoke to find herself undressed with a man on top of her, recognized appellant’s voice, and managed to kick him off after a struggle. Her mother, BBB, became suspicious after seeing appellant perspiring near the children that morning and later extracted a confession from AAA. A medical examination confirmed hymenal lacerations.
The defense presented a denial and alleged frame-up due to a family dispute over property. Appellant claimed he merely adjusted a sleeping child and was falsely accused. The Regional Trial Court convicted appellant of rape, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals affirmed the conviction but modified the penalty to include ineligibility for parole and imposed interest on damages.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for qualified rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications to the damages. The Court upheld the credibility of AAA’s testimony, which was clear, convincing, and consistent on the essential elements of the crime. The Court ruled that minor inconsistencies regarding peripheral details did not undermine her credibility but instead reinforced the naturalness of her narration. Her testimony was corroborated by her prompt outcry to her mother, the medical findings, and the conduct of the parties immediately after the incident.
The crime was properly qualified as rape under Article 266-B due to the victim’s minority (16 years old) and her relationship to the perpetrator as a relative within the third civil degree of consanguinity (uncle). Under the law at the time of the crime, the penalty would have been death, but with the effectivity of RA 9346 prohibiting the death penalty, the proper penalty is reclusion perpetua without eligibility for parole. Following prevailing jurisprudence, the Court increased the awards of civil indemnity, moral damages, and exemplary damages to Php100,000.00 each, all with legal interest from finality until fully paid.