G.R. No. 231386 . July 13, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

Three Informations charged accused-appellant XXX with raping his daughter, AAA. The first alleged rape occurred in June 1995 when AAA was 13 years old. The second was in October 1999 when she was 17. A third Information alleged repeated rape between June 1995 and October 1999. The prosecution evidence established that the rapes occurred in their shared sleeping area at night. Accused-appellant would carry AAA beside him, undress her, and have forcible intercourse while punching, slapping, and threatening to kill her mother if she resisted or reported the acts. This pattern was repeated on multiple occasions. In December 1999, AAA discovered she was pregnant, prompting her to reveal the abuse to her mother and report it to the police. Medical examination confirmed she was no longer a virgin and was 2-3 months pregnant, though she later miscarried.
The defense relied solely on denial and alibi. Accused-appellant claimed the charges were fabricated due to a misunderstanding because he could not afford a debut party for AAA’s 18th birthday. He denied all allegations of carrying, undressing, or having sexual intercourse with his daughter. The Regional Trial Court convicted accused-appellant of two counts of Qualified Rape and one count of Simple Rape. The Court of Appeals affirmed the RTC decision in toto, leading to this appeal.

ISSUE

The core issue is whether the prosecution proved the guilt of accused-appellant for the crimes of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalties and awards. The Court upheld the findings of the lower courts, giving great weight to the credible and categorical testimony of AAA. The defense of denial is inherently weak and cannot prevail over the positive, clear, and consistent narration of the victim, which was corroborated by medical findings. The alleged motive for fabrication—the denied debut party—is trivial and insufficient to overturn the conviction, especially given the gravity of the charges and the natural reluctance of a daughter to accuse her father falsely.
Regarding the charges, the Court applied the doctrine that a continuing crime of rape is not recognized in jurisprudence. Thus, the third Information (Criminal Case No. 00-2603(M)) alleging rape “in or about and between the period of June 1995 and October 1999” was duplicitous and void for failing to charge a definite offense. A single Information cannot charge multiple counts of rape over a multi-year period. Consequently, the conviction for this count (Simple Rape) was set aside. However, the two specific counts for June 1995 and October 1999, being properly alleged with sufficient definiteness, were upheld. The penalty for the qualified rape in October 1999 was reduced to reclusion perpetua, as the death penalty was not in effect at the time of its commission. The Court increased the damages awarded to the victim in line with prevailing jurisprudence, ordering accused-appellant to pay AAA P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages for each count of qualified rape, with legal interest.