GR 230981; (July, 2020) (Digest)
G.R. No. 230981 . July 15, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.
FACTS
The accused-appellant, the common-law husband of the victim’s mother, was charged with Rape under Article 266-A of the Revised Penal Code and for violating Section 5(b) of Republic Act No. 7610 (Special Protection of Children against Abuse, Exploitation and Discrimination Act). The victim, AAA, testified that when she was 12 years old, the accused-appellant, whom she called “Papa,” sexually assaulted her on multiple occasions. These acts included inserting his penis into her vagina and anus, and forcing her to perform oral sex. The abuse occurred inside their home and a nearby pigpen. AAA escaped and reported the incidents, leading to a medical examination which revealed old hymenal lacerations. A psychologist also diagnosed her with an anxiety disorder consistent with sexual abuse.
The accused-appellant denied the allegations, claiming the charges were fabricated because he had disciplined AAA for stealing. He argued it was incredible that he would commit rape while his own children were in the house. His live-in partner (AAA’s mother) and his own mother corroborated his defense, testifying they were usually present in the household and never witnessed any abuse.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt for the crimes of Rape and violation of RA 7610, despite his defense of denial and alibi.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s testimony was clear, candid, and consistent even under cross-examination. The Court found no ill motive for her to falsely accuse her stepfather, and her willingness to undergo the ordeal of a public trial bolstered her credibility. The medical findings, though indicating healed lacerations, corroborated her account of prior sexual intercourse. The defense of denial and alibi cannot prevail over the victim’s positive and credible identification. The Court also rejected the argument that the presence of other family members made the crime incredible, noting that rape can be committed even in occupied dwellings when the perpetrator finds an opportune time. The accused-appellant’s moral ascendancy as a stepfather facilitated the commission of the crime. Consequently, the Court upheld the penalties imposed by the lower courts: reclusion perpetua for rape and an indeterminate prison term for the violation of RA 7610, with corresponding damages awarded to the victim.